Paywatch Malaysia Sdn Bhd (“Paywatch”) sets out the following Privacy Policy which outlines the purpose, types, disclosures, rights to access and correction, as well as confidentiality to our customer’s or user’s (“User”) personal data collected. Paywatch refers to Paywatch Malaysia Sdn Bhd (Company No: 1394426-V) unless and to the extent otherwise stated.
This Privacy Policy is intended for individual customers and companies/ enterprises that have/ had a commercial relationship with us, or access/ have accessed our products and services. By using Paywatch products or services, you acknowledge that you have read and agreed to the terms of this Privacy Policy.

Collection of Personal Information

The information we collect is information that we require to perform our services and offer our products for you.
We may collect, and you hereby consent to such collection of, the following categories of personal data from and about you:

• Identifiers such as your name, nationality, date of birth, residential address, email address, social media handle, mobile number, identification card number/ passport number during the process of registration and/or eKYC.
• Employer information such as employer name, your employer’s address, your employer’s email address, your employer’s telephone number), or other addresses at which your employer can receive communications.
• Salary information such as your position, full/ part time status, work permit status, monthly salary, number of days worked per month, your work shifts when you bind your employment profile with Paywatch.
• App/ Web usage information: such as date of your first use of the App, frequency and amount of earned wage access withdrawn, frequency of access to the App or Website, frequency of use of the App or Website, browsing time on the App or Website, information collected through your interactions with our native feedback or complaint functionalities, and information about users or employers who refer you or whom you have referred.
• Location information: such as information related to your state, district, city, or neighbourhood, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Service.
• Financial information: such as information collected from you as needed to process salary advance requests, payments for advertisements, account creation, employer onboarding, or as provided by you to administer your participation in any Service, such as your bank and bank account number.
• Internet and network activity information (e.g. through your computer's IP address and cookies): such as information about your browsing behaviour, search history, and interactions with websites and advertisements (including the Website) such as data from cookies, pixel tags, and web beacons. We may use cookies for a number of purposes, such as to analyse your preference, for us to provide you with products and services, to improve our products and/or to personalise our services to you. If you do not wish to enable cookies, you may change the settings on your browser and/or mobile device.
• Inferences regarding preferences and other characteristics: such as our assessment of the types of user settings you prefer or a Service you may have an interest in.

Some information is required by Paywatch to fulfil partly or all of the services requested by you. If you are unable to provide us with the required information, we may not be able to fulfil your request and, as a result, you may encounter some inconveniences while using our services. You may choose to give us personal information directly in a variety of situations. For example, you may want to give us your name and contact information to communicate with you to register for a service, to provide you with earned wage access, or to do business with us if you are a supplier or business partners.
There is also information which we may collect from written communication when you provide us feedback(s) or contact us (e.g. your name and email address, as well as any other content included in your written communication to us) and we may use it for the purposes of communicating with you and to efficiently manage your requests and to resolve any other issues you may face.
From time to time, we may also collect information that pertains to you indirectly through other sources (if any). When we do so, we require the third party to confirm that the information was legally acquired by them and that they have obtained your consent for us to use it. This includes but is not limited to, information collected through eKYC procedures to confirm your identity, and from your employer (or software utilised by your employer such as HRIS or HRMS software) to confirm your one-off and ongoing employment details. We may also collect information from publicly available sources. The information that we collect, either directly or indirectly, may be combined to help us improve its overall accuracy and completeness and to help us better tailor our interactions with you.
We may obtain information about you or your use of the Service from third party sources, such as social media networks, our vendors, web hosting providers, analytics providers, or advertisers. You may give us permission to access your information from services offered by third parties, including social media networks. The information we obtain from third party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies. When you access the Service through social media networks and other third-party platforms, you are authorising Paywatch to collect, store, and use such information and content in accordance with this Privacy Policy. Please keep in mind that any information provided to us by a third party may also be subject to that third party's privacy policy.
As a parent or legal guardian, please do not allow minors under the age of 18 under your care to submit Personal Data to Paywatch. In the event that such Personal Data of a minor is disclosed to Paywatch, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Notice and take responsibility for his or her actions.

Use of Personal Information

We collect your Data to provide you with the requested services, and to meet your needs and objectives. We may for the purposes below as well as those incidental and associated with any of the below.

Evaluation and processing of application

We may use your personal data to evaluate your application for use of our products and services, as well as to process your application for our products and services. This may include conducting credit checks.

Establishing relationships

We may use your personal data to establish a relationship between you, Paywatch, the financial institutions and/or companies related to or affiliated to us, our service providers and business partners.

Fulfilling of Product/ Service and Transaction Requests

For the overall provision of products and services to you, primarily but not limited to provision through electronic means. If you request something from Paywatch, for example, a product or service, we may use the information you provide to fulfil your request. Such relevant information will be necessary for us to provide you with such product or service. To help us do this, we may share information with others, for instance, Paywatch's business partners, Paywatch related company and financial institutions involved in fulfilment. In connection with a transaction, we may also contact you as part of our user satisfaction surveys or for market research purposes.

Personalizing your Experience on our Websites

We may use information we collect about you to provide you with a personalized experience on our websites, such as providing you with content in which you may be interested and making navigation on our sites easier.

Marketing & Research

The information you provide to Paywatch, as well as the information we have collected about you indirectly, may be used by Paywatch, your employer and Paywatch business partners for marketing, research, and to jointly develop products and services that may involve the sharing of your data.
Paywatch may extract, disclose and release the information in the possession of Paywatch relating to you with your employer and Paywatch business partners. However, please note that we will only disclose your personal information subject at all times to any laws, regulations, guidelines and/or obligations applicable to Paywatch.
The information that we may disclose for the purposes of research and marketing may include but not limited to the following:

• Personal information such as name, date of birth, age.
• Contact information including address, phone numbers and email address.
• Users' work activity, withdrawal and repayment details for marketing and analysis purposes

If you choose to withdraw your consent for receiving marketing or promotional materials/communication, you may contact us using the contact details found below. Please note that even if you opt out from receiving marketing or promotional materials, Paywatch may still contact you for other purposes in relation to the accounts or services that you have subscribed to with Paywatch.
Where Paywatch wishes to share your information with your employers and Paywatch business partners for research, marketing and promotional purposes, Paywatch will only disclose your personal information to our business partners where your express prior consent has been obtained and subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to the Paywatch.
Your data may be used or processed by Paywatch to administer offers, competitions and promotions, for the research and development of new products and services for user’s use. It will also allow us, our related and/or affiliated companies, service providers and business partners to promote their products and services.

Protect the Rights and Property of Paywatch and Others

We may also use or share your information to protect the rights or property of Paywatch, our business partners, suppliers, clients, or others when we have reasonable grounds to believe that such rights or property have been or could be affected. In addition, we reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights, or the rights of others, or to comply with a judicial proceeding, court order, or legal process served on our websites.

Debt Collection and other Legal Enforcement

Your data may be used or processed by us, or our service providers for debt collection purposes, and for enforcement or defense of our rights and obligations of other parties to us and/or our affiliates.
It also will allow us to prevent fraud or detect crime or for the purpose of investigation, for audit and risk management
For any proposed or actual merger, sale, transfer or proposed transfer of any part of our interests, assets, obligations, business and/or operations

Communications

Your data may be used or processed by us to respond to inquiries or complaints from you and for dispute resolution.

Collection and Use of Non-Personal Information

We also collect non-personal information/data in a form that does not permit direct association with any specific individual. We may collect, use, transfer and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

We may collect information such as occupation, language, postcode, area code, unique device identifier, location and the time zone where the Paywatch products or services are used, so that we can better understand user behaviour and improve our products, services and advertising.

We also may collect information regarding user activities on our websites and app and from our other products and services. This information is aggregated and used to help us provide more useful information to our users and to understand which parts of our websites, products and services are of most interest. Aggregated data is considered nonpersonal information for the purposes of this Privacy Statement.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Disclosure of Information

Paywatch complies with the data protection laws in Malaysia and takes all reasonable care to prevent any unauthorized access to your personal data. Paywatch and those working for agents or contractors of Paywatch have the responsibility to keep your information confidential and will only use it to offer products and services on behalf of Paywatch.

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

The classes of third parties that Paywatch may divulge the personal information of its users are as follows:

• Any financial institution granting or intending to grant any credit/financing facilities to you, the Central Credit Bureau or any other central credit bureau established by Bank Negara Malaysia,, any other relevant authority as may be authorised by law to obtain such information, authorities/agencies established by Bank Negara Malaysia and/or any other person as may be authorised by law or any governmental authority and/or regulatory authority and/or any industry related association.
• Persons/organizations required under law or where disclosure is necessary for the purposes of compliance with applicable laws or in response to relevant authorities’ requests.
• Government agencies, statutory authorities, enforcement agencies under law.
• Paywatch auditors, accountants, solicitors, tax advisors, investment banks and other professional advisors appointed by us.
• Any credit reference agency, debt collection agencies, rating agency correspondents, direct or indirect provider of credit protection and fraud prevention agencies.
• Any insurance company/takaful operators, brokerage and any association or federation of insurance companies/takaful operators.
• Companies and/or organisations (including their authorised representative) which are our agents, affiliates, service providers and/or business partners, in or outside Malaysia that are deemed necessary or appropriate for the purposes stated above including for the purposes of fraud investigation.
• Persons under a duty of confidentiality to Paywatch.
• Government authorities or relevant parties for the purpose of investigation on any matters relating to the card or any products offered by the Paywatch.
• Any class of third parties expressly stated in this Privacy Statement.
• Any person or corporation to whom we merge/transfer/sell or proposed to merge/transfer/sell any part of its interests, assets, obligations, business and/or operations.
• Any person by whom we are required by applicable legal, governmental or regulatory requirements to make disclosure.
• Any other person reasonably requiring the same in order for us to carry out the activities set out in the above purposes

For the avoidance of doubt, Paywatch shares its users’ personal information with companies who provide services such as information processing, extending credit or financing, managing and enhancing users’ data, providing user service, assessing users’ interest in Paywatch’s products and services, and conducting user research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Paywatch operates (including those located out of Malaysia, under conditions of confidentiality and similar levels of security).

Information Security and Accuracy

Paywatch takes precautions including administrative, technical, and physical measures to safeguard your personal information against loss, theft, and misuse, as well as against unauthorised access, disclosure, alteration and destruction. Furthermore, we intend to protect your personal information and to maintain its accuracy. Paywatch implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure.

Integrity and Retention of Personal Information

Paywatch makes it easy for you to keep your personal information accurate, complete and up to date. We will only retain your personal data for as long as necessary to fulfil the purpose(s) for which it was collected or to comply with legal, regulatory, and internal requirements. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Notice , or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

Access and Correction to Personal Information

We are committed to ensure that the personal data we hold about you is accurate, complete, not misleading and up-to-date. 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.

You have the right to access your personal data. If you would like to request access to your personal data, please contact us. We may also take steps to verify your identity before fulfilling your request for access to your personal data.

Paywatch reserves the right to decline to process requests:

• Where Paywatch is not supplied with sufficient information as to the identity of the requestor or of the relevant person making the request;
• Where Paywatch is not supplied with sufficient information to enable it to locate the personal data;
• Where the burden or expense of providing access is not proportionate to the risk of the data subject’s privacy;
• Where Paywatch cannot comply with the request without disclosing the personal data of another individual who is identifiable from that information. However, this can be provided if Paywatch is satisfied that the other individual has consented to the disclosure of the information to the requestor or it is reasonable in all circumstances to comply without the consent of such other individual;
• The processing of personal data is controlled by another data user in a manner which prohibits the relevant data user from complying in whole or part with the request;
• Where it will be against any court order;
• Where it will disclose confidential commercial information; or
• Where the access is regulated by another law.

Access, correction, deletion requests or any enquiries and complaints can be made to:

Paywatch Malaysia Sdn Bhd

(i) online via Paywatch’s Malaysia website Contact Form https://www.paywatchglobal.com/my/contactUs; or

(ii) by emailing backoffice@paywatchglobal.com

Paywatch will use reasonable efforts to comply with your request to access or correct your personal information within 21 days of receiving your request to change the same and charge the relevant processing fee (if any).

However, choosing not to share your Personal Data with us or withdrawing your consent to our use of it could mean that we are unable to proceed with the provision of the relevant product or services and you may not be able to use such product and services thereafter. After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

Third-Party Sites and Services

Paywatch Websites, products, applications and services may contain links to third-party websites, products and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details are governed by their privacy practices. This means, third party internet sites that you can link through Paywatch are not covered by our policy. Therefore, we encourage you to familiarise with those third parties’ sites’ privacy policies before using the links or applications and we urge you to be careful when you enter any personal information online. Paywatch accepts no responsibility or liability for those sites.

Use of Cookies

Paywatch, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (“Cookies”) in connection with your use of the Websites and Apps. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our use of mobile identifiers (such as Apple’s IDFA). Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

Paywatch may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes Paywatch does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.

Disabling the collection of cookies on our websites

You may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser.

Our Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to Paywatch employees and strictly enforce privacy safeguards within the company.

Changes to this Privacy Statement

Please note that we may update this Privacy Notice from time to time. If there are material changes to this Privacy Notice, we will notify you by posting a notice of such changes on our website or by sending you a notification directly. Do periodically review this Privacy Notice to stay informed on how we are protecting your information.

This Privacy Notice was last updated in December 2021.

Questions or Concerns

If you have any question or concern, you may contact the following: Paywatch Malaysia Support Team backoffice@paywatchglobal.com