Effective Date: 15 May 2026 · Version 1.2

Paywatch Global Pte. Ltd. and/or its subsidiaries (“Paywatch”, “we”, “us” or “our”) sets out the following Privacy Policy, which outlines the purpose, types, disclosures, rights to access and correction, as well as confidentiality regarding our customers’ or users’ (“User”) Personal Data collected.

This Privacy Policy is intended for individual customers, business partners, vendors, and suppliers who have or had a commercial relationship with us or have accessed or currently access our products and services (“Services”). By using Paywatch products or services, you acknowledge that you have read and agreed to the terms of this Privacy Policy.

Scope of Personal Data

The Personal Data we collect is information that we require in order to perform our services and offer our products to you.

We may collect, and you hereby consent to the collection of, your Personal Data, which refers to any information about you that identifies you. This includes the following categories of information:

Identifiers such as your name, nationality, date of birth, residential address, email address, social media handle, mobile number, and identification card or passport number, collected during the registration process and/or eKYC.
Employer information such as your employer’s name, employer’s address, employer’s email address, employer’s telephone number, or other addresses where your employer can receive communications.
Salary information such as your position, full-time or part-time status, work permit status, monthly salary, number of days worked per month, and your work shifts when you link your employment profile with Paywatch.
App/Web usage information such as the date of your first use of the app, frequency and amount of earned wage access withdrawn, frequency of access to the app or website, frequency of use of the app or website, browsing time on the app or website, information collected through 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 details related to your state, district, city, or neighbourhood. If you agree, we may also collect more specific location information provided through the GPS functionality on mobile devices used to access the service.
Financial information such as data collected from you in order to process salary advance requests, payments for advertisements, account creation, employer onboarding, or to administer your participation in any service, including your bank details and bank account number.
Internet and network activity information (e.g., through your computer’s IP address and cookies) such as details about your browsing behavior, search history, and interactions with websites and advertisements (including the website). This includes data from cookies, pixel tags, and web beacons. We may use cookies for several purposes, including analyzing your preferences, providing you with products and services, improving our products, and personalizing our services for you. If you do not wish to enable cookies, you may change the settings on your browser or mobile device.
Inferences regarding preferences and other characteristics such as our assessment of the types of user settings you prefer or services you may be interested in.

Collection of Personal Data

By agreeing to this Privacy Policy, you consent to the collection of your Personal Data by Paywatch for further processing to enable us to provide the Services to you. The term “processing” includes data processing, analysis, storage, transfer, disclosure, removal, erasure, and other actions we may perform in relation to the Personal Data as strictly required by Paywatch in accordance with this Privacy Policy and applicable laws and regulations.

Paywatch requires your Personal Data to fulfill partly or fully the services requested by you. If you are unable to provide us with the required information, we may not be able to fulfill your request, and as a result, you may encounter some inconvenience while using our services. You may choose to provide us with Personal Data directly in various situations. For example, you may provide us with your name and contact information to communicate with you, register for a service, provide earned wage access, or engage in business with us if you are a supplier or business partner.

We may also collect Personal Data from written communications when you provide us with feedback or contact us (e.g., your name, email address, and any other content included in your communication). We may use this data to communicate with you, manage your requests efficiently, and resolve any issues you may face.

We may also collect your Personal Data by monitoring and recording all transactions and communications that take place between us and you for business purposes (including but not limited to quality control, training, preventing unauthorized use of Paywatch’s telecommunication systems, ensuring effective systems operation, and detecting and preventing crime).

From time to time, we may also collect Personal Data indirectly from other sources. When we do so, we require the third party to confirm that the information was legally obtained 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 verify your identity, and information from your employer (or software used by your employer, such as HRIS or HRMS software) to confirm your one-time and ongoing employment details. We may also collect information from publicly available sources. The information we collect, either directly or indirectly, may be combined to improve its overall accuracy and completeness and to help us tailor our interactions with you.

We may obtain information about you or your use of the services 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 their privacy policies. When you access the services through social media networks or other third-party platforms, you are authorizing 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, agree to be bound by this Privacy Policy, and take responsibility for their actions.

Use of Personal Data

We collect your Personal Data to provide you with the requested services and to meet your needs and objectives. Your Personal Data is processed where you have given consent, or where we have a lawful basis to do so, such as:

To comply with applicable laws and regulations
To perform or enter into contractual arrangements with you
To fulfill our legitimate interests

We will process your Personal Data for the purposes outlined below, as well as for purposes necessarily associated with any of the following:

i. Evaluation and Processing of Applications

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

ii. 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 with us, our service providers, and business partners.

iii. Fulfilling Product/Service and Transaction Requests

We may use your Personal Data to provide products and services to you, primarily through electronic means, though not exclusively. If you request something from Paywatch, such as a product or service, we may use the information you provide to fulfil your request. To do this, we may need to share your Personal Data with others, such as Paywatch’s business partners, affiliated companies, and financial institutions involved in the fulfilment process. In connection with a transaction, we may also contact you as part of user satisfaction surveys or for market research purposes.

iv. Personalizing your Experience on our Websites

We may use the Personal Data we collect about you to provide a personalized experience on our websites or Paywatch mobile application (“Application”), such as offering content that may interest you and making navigation on our sites easier.

v. Marketing & Research

The Personal Data you provide to Paywatch, as well as the Personal Data we have collected about you indirectly, may be used by Paywatch, your employer, and Paywatch business partners for marketing, research, and the joint development of products and services that may involve the sharing of your data.

Paywatch may extract, disclose, and release the Personal Data in its possession relating to you to your employer and Paywatch business partners. However, please note that we will only disclose your Personal Data in compliance with applicable laws, regulations, guidelines, and/or obligations.

The Personal Data we may disclose for research and marketing purposes may include, but is not limited to, the following:

Personal Data such as name, date of birth, and 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 to receive marketing or promotional materials/communications, you may contact us using the contact details provided below. Please note that even if you opt out of receiving marketing or promotional materials, Paywatch may still contact you for other purposes related to the accounts or services you have subscribed to with Paywatch.

Where Paywatch wishes to share your Personal Data with your employer and Paywatch business partners for research, marketing, and promotional purposes, Paywatch will only disclose your Personal Data to our business partners if your express prior consent has been obtained and in compliance with any applicable laws (including regulations, guidelines, and/or obligations).

Your Personal Data may be used or processed by Paywatch to administer offers, competitions, and promotions, and for the research and development of new products and services for users. This will also allow us, our related and/or affiliated companies, service providers, and business partners to promote their products and services.

vi. Protect the Rights and Property of Paywatch and Others

We may also use or share your Personal Data 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 Data as required by law and when we believe that disclosure is necessary to protect our rights, the rights of others, or to comply with judicial proceedings, court orders, or legal processes served on our websites.

vii. Legal Enforcement and Risk Management

Your data may be used or processed by us or our service providers for debt collection purposes, involving our business partners and vendors, as well as for the enforcement or defense of our rights and the obligations of other parties to us and/or our affiliates.

In addition, your Personal Data may also be used to assess and manage risk, including to prevent and/or identify the commission of fraud, detect crime, or for investigative purposes.

viii. Communications

Your Personal Data may be used or processed by us to respond to inquiries or complaints from you and for dispute resolution. In addition to the above, Paywatch may also use your Personal Data for administrative purposes and other matters related to the provision of Services by Paywatch.

Collection and Use of Non-Personal Information/Data

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 Paywatch products or services are used, in order to better understand user behavior and improve our products, services, and advertising.

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

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

Disclosure of Information

Paywatch complies with local data protection laws and takes all reasonable care to prevent unauthorized access to your personal data. Paywatch and those working as 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.

Personal Data shared with third parties will be for the purpose as stated in this Privacy Policy, or purposes not stated but directly related to the primary purpose of collection. Data sharing may be done with entities within or outside of Paywatch’s countries. Please refer to the “Data Transfer” section below for our policy regarding the sharing of personal data with entities inside or outside of Paywatch’s countries.

The categories of third parties to whom Paywatch may disclose the personal data of its users include:

Persons or organizations required under law, or where disclosure is necessary for compliance with applicable laws or in response to relevant authorities’ requests.
Government agencies, statutory authorities, and enforcement agencies under law.
Paywatch auditors, accountants, solicitors, tax advisors, investment banks, and other professional advisors appointed by us.
Any credit reference agency, central credit bureaus, debt collection agencies, rating agency correspondents, direct or indirect providers of credit protection, and fraud prevention agencies.
Any insurance company/takaful operators, brokerage firms, and any association or federation of insurance companies/takaful operators.
Companies and/or organizations (including their authorized representatives) that are our agents, affiliates, service providers, and/or business partners, deemed necessary or appropriate for the purposes stated above, including fraud investigations.
Persons under a duty of confidentiality to Paywatch.
Government authorities or relevant parties for the purpose of investigating any matters related to any products offered by Paywatch.
Any third party expressly stated in this Privacy Policy.
Any person or corporation to whom we merge, transfer, or sell, or propose to merge, transfer, or sell, any part of our interests, assets, obligations, business, and/or operations.
Any person to 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 that 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.

International Transfer

In order to provide you with the Services, Paywatch may need to transfer your Personal Data to third parties located within or outside the countries of Paywatch, where necessary for purposes including centralized processing and regional operations. You hereby authorize Paywatch to perform such data transfers to parties located within or outside these countries. These third parties may store and process your Personal Data outside the countries of Paywatch for the benefit of Paywatch, in accordance with the purposes and terms set out herein. We safeguard cross-border transfers of your Personal Data through putting appropriate technical and organizational safeguards, contractual arrangements with our subsidiaries, affiliates, and business partners that require them to uphold equivalent data protection standards.

Users’ Rights

Under applicable privacy regulations, you may be entitled to the below rights in respect of your Personal Data:

to complete, update and/or rectify errors and/or inaccuracies of your Personal Data as further regulated under section “Access and Correction to Personal Information” below;
to access and obtain a copy of your Personal Data;
to request an end to the processing of, deletion, and/or destruction of your Personal Data, although these actions may affect the provision of the Service;
to withdraw your consent for the processing of your Personal Data, although doing so may affect the provision of the Service;
to object to a decision-making action that is based solely on automated processing, including profiling, which has legal consequences or have a significant impact on yourself as the owner of the Personal Data;
to delay or limit the processing of your Personal Data as appropriate to the purpose of data processing; and
to request a transfer of your data to another organization, in a structured and machine-readable format.

All of your rights should be interpreted within the qualifications provided by the applicable laws and regulations and may therefore be limited in certain circumstances as permitted by these laws and regulations.

Automated Decision Making

Paywatch receives employment data from your employer or their HR/payroll systems, which may use automatic means to assess your eligibility for our earned wage access services, we do not make decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant impacts on you. Decisions relating to the provision of our services involve authorized personnel, ensuring that your rights and interests are protected with appropriate human oversight.

Information Security and Accuracy

Paywatch takes precautions, including administrative, technical, and physical measures, to safeguard your Personal Data against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. We are committed to protecting your Personal Data and maintaining its accuracy. Paywatch implements reasonable safeguards in all these areas to help protect your Personal Data from unauthorized access, use, and disclosure.

Integrity and Retention of Personal Information

Paywatch may store your Personal Data in our data storage systems or in data storage maintained by third parties, both within and outside the countries where Paywatch operates. In storing your Personal Data, Paywatch ensures that it remains accurate, complete, and up to date. We will retain your Personal Data only for as long as necessary to fulfill 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 reason to retain it, we will take steps to erase, destroy, anonymize, or prevent access to or use of the data, except for purposes related to compliance with this Privacy Policy, or for safety, security, fraud prevention, and detection, in accordance with applicable laws.

Access and Correction to Personal Information

We are committed to ensuring 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 hold is inaccurate, incomplete, misleading, or outdated, please contact us so that we can take steps to update your Personal Data.

You have the right to access your Personal Data. If you would like to request access, please contact us. We verify all requests to protect your rights and may ask for additional information or documentation. Once verified, we will process your request within the timelines prescribed by applicable laws.

Paywatch reserves the right to decline requests to process the following:

Where Paywatch is not supplied with sufficient information to identify the requestor or the relevant person making the request;
Where Paywatch is not supplied with enough information to locate the Personal Data;
Where the burden or expense of providing access is disproportionate to the risk to the data subject’s privacy;
Where complying with the request would disclose 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 or if it is reasonable in all circumstances to comply without such consent;
Where the processing of Personal Data is controlled by another data user in a way that prohibits compliance with the request in whole or in part;
Where compliance would violate a court order;
Where complying would disclose confidential commercial information; or
Where access is governed by another law to which the User is subject, and such law does not require the disclosure of the Personal Data.

Requests for access, correction, deletion, or any enquiries and complaints can be made to:

Paywatch Global Pte. Ltd.

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

(ii) By emailing our Data Protection Officer: dpo@paywatchglobal.com

Paywatch will make reasonable efforts to comply with your request to access or correct your personal information request and may charge a relevant processing fee (if any).

However, choosing not to share your Personal Data with us or withdrawing your consent may mean we are unable to proceed with providing the relevant products or services, and you may no longer be able to use such products or services. After withdrawing your consent, we may continue to process your Personal Data to the extent required or 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 these third parties, which may include location data or contact details, is governed by their privacy practices. This means that third-party websites you link to through Paywatch are not covered by our privacy policy. Therefore, we encourage you to familiarize yourself with the privacy policies of those third-party sites before using the links or applications. We urge you to be cautious when entering any personal information online. Paywatch accepts no responsibility or liability for those third-party 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 system you are using, you may have 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 related 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 can deactivate cookies by adjusting your internet browser settings to disable, block, or remove them, as well as by deleting your browsing history and clearing the cache.

Our Commitment to Your Privacy

To ensure the security of your personal data, we communicate our privacy and security guidelines to Paywatch employees and strictly enforce privacy safeguards within the company.

Changes to this Privacy Policy

Please note that we may update this Privacy Policy from time to time. If there are material changes, we will notify you by posting a notice on our website or by sending you a direct notification. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information. Your continued use of the Service constitutes your consent to any amendments to the Privacy Policy.

Governing Law

This Privacy Policy is governed by, and shall be construed in accordance with, the laws of the respective countries.

Language

This Privacy Policy is prepared in English and may also be written in other languages of respective countries. In the event of any conflict or inconsistency between the English text and the respective country’s language text, or in their interpretation, the respective country’s language text shall prevail. The English text will be deemed amended to align with the corresponding text and its meaning.

Severability

If any provision of this Privacy Policy is held to be illegal, invalid, or unenforceable, in whole or in part, in any jurisdiction, the remaining provisions of this Privacy Policy shall remain valid in that jurisdiction. The legality, validity, and enforceability of the affected provision in any other jurisdiction shall remain unaffected.

This Privacy Policy was last updated in May 2026.

Questions or Concerns

If you have any questions or concerns, please contact our Data Protection Officer at dpo@paywatchglobal.com.