Effective Date: 18th May 2021

This Personal Data Protection Policy (Personal Data Protection Policy) explains how Payd Sdn. Bhd., its affiliates, and its subsidiaries (Payd, we, us or our) use your personal data and this Personal Data Protection Policy applies to anyone who downloads, uses, installs or accesses any part of the “Payd – your money” mobile application software (App), the website maintained at www.justpayd.com (Website) or other online services or any of our described activities that we own or control and all associated products and features that we may offer from time to time (collectively, the Service).

For terms that govern the use of the Service, please review the Terms of Service.

By using the Service, you acknowledge that you have read and agreed to the terms of this Personal Data Protection Policy. If you do not want your personal data handled as described in this Personal Data Protection Policy, please do not provide us with your personal data or interact with the Service. If you choose not to provide the necessary personal data to us, we may not be able to provide you with the Service or allow you to set up an account.

We may modify this Personal Data Protection Policy at any time. You are deemed to agree and consent to any changes in this Personal Data Protection Policy by way of your continued use of the Service.

If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of notice on the Service prior to the change becoming effective. You can determine when this Personal Data Protection Policy was last revised by referring to the Effective Date above.

Personal data, as used in this Personal Data Protection Policy, shall have the definition ascribed to it under the Personal Data Protection Act 2010 (Act 709). Defined terms shall have the meaning ascribed to them in the Terms of Service unless the context otherwise admits. To the extent that this Personal Data Protection Policy varies or modifies any provision of the Terms of Service, the term in the Personal Data Protection Policy prevails.

Types of information we collect
We may collect, and you hereby consent to such collection of, the following categories of personal data from and about you:

1. Identifiers: such as your name, nationality or ethnic origin, postal addresses, email addresses, account information, social media account handle(s), telephone numbers, or other addresses at which you are able to receive communications.

2. Demographic information: such as your age, birthdate, and gender.

3. Employer information: such as your employer, your employer’s postal address, your employer’s email address, your employer’s telephone number, your employer’s fax number, your employer’s social media account handle(s), or other addresses at which your employer is able to receive communications.

4. Salary information: such as your position, your full-time/part-time status, work permit status (for non-Malaysian employees), monthly salary, the number of days worked per month, your contributions under the Employees Provident Fund Act 1991 (Act 452) (EPF), your contributions under the Employees’ Social Security Act 1969 (Act 4) (SOCSO), your contributions under the Employment Insurance System Act 2017 (Act 800) (EIS), any Potongan Cukai Bulanan (PCB) deductions, any zakat deductions, any prior advances under section 22 of the Employment Act 1955 (Act 265), any employee loans or any other information that may affect your Earned Wage Access entitlement.

5. Commercial information: such as date of your first use of the App, frequency and amount of Earned Wage Access, 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.

6. 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.

7. Financial information: such as information collected from you as needed to process Earned Wage Access payments, payments for advertisements, account creation, employer onboarding, or as provided by you to administer your participation in any Service, such as your bank, your bank account number, and where necessary, your international bank account number (IBAN), your Sort Code, your Swift Code, your IFSC Code, your ABA Routing Transit Number, your Bank State Branch number (BSB), any other bank identifier code (BIC), your payment card number, expiration date, and card verification code (CVC).

8. Internet and network activity information: 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.

9. 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.

How Payd collects information
We may collect personal data about you from a variety of sources, including:

1. From you: We collect information that you submit to us. For example, when you create an account; submit feedback; register to receive information available through the Service; or interact with us in other ways. We will collect any information you voluntarily provide, and we may also request optional information to support your use of the Service. We also collect any information that you voluntarily enter into any of the available native functionalities within the Service. If you send an e-mail to us, we will collect your e-mail address and the full content of your e-mail, including attached files and other information you choose to provide to us.

2. From your employer: We may integrate with your employer’s human resources platform to receive information to determine your entitlement to any Earned Wage Access and we may contact your employer directly to validate any employment information or entitlement to any Earned Wage Access.

3. From your device: When you use the Service, we may collect information about the devices you use to access the Service, including hardware model, operating system and version, Internet Protocol (IP) address, and other unique device identifiers, mobile network information, and information about the device’s interaction with our Service. We also collect information about how you use our Service, including your access times, browser types, and language. This type of data enables us to understand how often individuals use parts of the Service so we can analyse and improve it. To collect this information, we use cookies and web beacons, and other similar technologies. To learn more about how we automatically receive and record information when you interact with the Service, please review our Cookie Policy. Note that this Personal Data Protection Policy does not cover the use of such information by third parties.

4. Location information: We may collect different types of information about your location, including general information, such as the city, state, district and/or post code associated with your IP address, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Service. We may use such location information to customise the Service, including advertising, that is presented to you. In order to do this, your location information may be passed along to our affiliates, agents, vendors or advertisers. You may be able to disallow our use of certain location data through your device or browser settings.

5. Social media networks and other third parties: We may obtain information about you or your use of the Service from third party sources, such as 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 Payd to collect, store, and use such information and content in accordance with this Personal Data Protection 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.

How Payd uses information
We may use information collected as described in this Personal Data Protection Policy to:

1. Operate, maintain, and improve the Service and other features, and functionalities related to the Service;
2. Allow you to make a complaint, submit feedback, submit error, crash or bug reports;
3. Provide you with interest-based advertisements, push notifications, communications, and other goods and services related to the Service, including based on your precise geolocation;
4. Disclose or publish the personal data to your employer for the purposes of notifying your employer of any Earned Wage Access and facilitating monthly reimbursements;
5. Disclosing the personal data to third-party messaging services to send out alerts or other communications;
6. Process your Earned Wage Access;
7. Evaluate your eligibility for certain types of promotions or services that may be of interest to you, and analyse advertising effectiveness;
8. Evaluate your reviews and answer your questions;
9. Perform analytics and conduct customer research;
10. Communicate and provide additional information that may be of interest to you about Payd and our business partners, sometimes by combining your information with information we obtain from other sources;
11. Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information, including on behalf of our business partners;
12. Administer surveys or other activities or events sponsored by us or our business partners;
13. Manage our everyday business needs, such as administration of the Service, content management, fulfilment, analytics, fraud prevention, and enforcement of our corporate reporting obligations, or our Terms of Service, or to comply with the law;
14. Allow you to apply for a job;
15. Verify your requests made pursuant to this Personal Data Protection Policy, and;
16. Enhance other information we have about you to help us better understand you and determine your interests.

We also may use information collected as described in this Personal Data Protection Policy with your consent or as otherwise required or permitted by law.

If you use any features on the Service to send information about the Service to another person, including another user, we will also collect the personal data of that other person to the extent disclosed by you and may contact them using the information you provided us.

When and why Payd discloses information
We may share your personal data as follows:

1. As required to comply with the law or legal obligations, such as to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions;
2. In response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in Malaysia and other countries where we operate;
3. With our professional advisers, such as our lawyers and accountants, with a view to obtain professional advice;
4. With our vendors who perform a variety of services and functions for us, such as data storage, order fulfilment, transmitting emails, and managing digital content. We may share your information with such vendors subject to confidentiality obligations consistent with this Personal Data Protection Policy and on the condition that the service providers use your information only on our behalf and pursuant to our instructions;
5. In the event we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganisation, or sale of all or a portion of our assets;
6. To combat fraud or criminal activity, and to protect our rights, Users and business partners, or as part of legal proceedings affecting Payd or its related corporations;
7. With our auditors to ensure the compliance of your employer or any other third party with any instrument or agreement;
8. With our affiliates and subsidiaries who may only use the personal data for the purposes described in this Personal Data Protection Policy;
9. If the information has been aggregated, de-identified, anonymised or otherwise does not identify you personally; or
10. Otherwise with your consent.

Security of Personal Data
Payd has implemented an information security program that contains administrative, technical, and physical controls that are designed to reasonably safeguard personal data that is compliant with the Personal Data Protection Standard 2015. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

Pursuant to this, you hereby consent to your personal data being stored in secure facilities on the Cloud and acknowledge that your personal data may be processed, stored and analysed outside of Malaysia.

Your rights regarding personal data
You have certain rights with regard to your personal data:

1. You have the right to know and request information about the categories and specific personal data we have collected about you within the last twelve (12) months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal data for business purposes;
2. You have the right to correct or update your personal data;
3. You have the right to request a copy of your personal data;
4. You have the right to withdraw consent for further processing of your personal data;
5. You have the right to request for us to cease processing your personal data if such processing is likely to cause damage or distress; and
6. You have the right to request for us to cease processing your personal data for the purposes of direct marketing.

Contact us
Please contact us if you have any questions or comments about our privacy practices or this Personal Data Protection Policy.
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You can reach us online at hello@justpayd.com.