Personal Data Protection Act (PDPA)

At Finlit Technologies Sdn. Bhd. (1623877-K), we are committed to protecting your privacy in accordance with the Personal Data Protection Act 2010 of Malaysia (“PDPA”). This Policy explains:

• the type of personal data we collect and how we collect it
• how we use your personal data
• the parties that we disclose the personal data to; and
• the choices we offer, including how to access and update your personal data.

Personal Data that we may collect from you

We may collect the following personal data about you:

• personal information to establish your identity and background such as your full name, passport or identity card number, nationality and religion
• contact information such as billing address, premises address, telephone number, mobile phone number, fax number and email address
• account and sign-in information: the name and email address shared with us by Google or Apple when you sign in with them, the email address you sign up with, and, if you connect one, your WhatsApp phone number
• what you record in the MoneyMama app: the expenses, income, budgets, reminders and other financial details you enter or tell MoneyMama, receipt photos you take or choose from your photo library, and statements you import. Voice notes are transcribed to text so MoneyMama can read them; the audio recording itself is not saved
• app usage and device information: which screens and features you use in the app and basic details about your device, and, if you allow push notifications, the token your phone's notification service issues so we can deliver them
• payment information: when you pay for a paid service, your card details are collected by our payment processor. We receive confirmation of the payment, the amount and the last four digits of the card; we do not store your full card number
• if you lock the app with Face ID, fingerprint or a passcode, the check is done by your phone's operating system and no biometric data is collected by us or sent to us
• financial documents and statements that you upload to our debt-management tools, such as credit card statements, bank or account statements, and loan or financing statements, together with the information contained in them (for example, account or card numbers, outstanding balances, transaction history, dates and amounts, minimum payments, and interest, profit, or fee charges)
• sensitive information such as your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership. We do not generally collect sensitive information unless it is necessary due to exceptional circumstances to serve you better and meet your particular needs
• recording of your photograph during any of our corporate events or third party open day
• recording of calls placed by you to our customer services
• function or post when you commence a business relationship with us
• resume or CVs when you apply job with us

For general web browsing although no personal data is revealed to us, certain technical and statistical information is available to us via our internet service provider such as cookies, your IP address, the time, date and duration of your visit. If you provide us with any personal data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such personal data to us, you represent to us that you have obtained the consent of the third party to provide us with their personal data for the purposes as listed below.

How We Collect Your Personal Data

We may collect personal data either from you, from your authorized representatives, from third parties, or from publicly available sources which may include (but is not limited to):

• when you register for our services (for example when you submit a form to become our customer)
• when you contact us in person, by a phone call or over the counter (for example when you contact us for any enquiries, complaints, comments or feedbacks, we may keep record of that correspondences)
• when you participate in any surveys, questionnaires, competitions, contests, offers, or promotions done internally or via an appointed third party
• when you commence a business relationship with us (for example, as a service provider, or business partner)
• when you attend any of our corporate events or third party open day
• when you visit or browse our websites
• when you apply job with us
• when you interact with us via social media or interactive applications including but not limited to Facebook, TikTok, and Instagram
• when we collect information about you from third parties we dealt with or are connected with you
• from such other sources where you have given your consent for the disclosure of personal data relating to you, and/or where otherwise lawfully permitted.

Use of Personal Data Collected

You agree that we may use your personal data where permitted by applicable law and for the following purposes:

• to verify your identity
• to manage and maintain your account or contract with us
• to notify you about benefits and changes to the services
• to provide and improve our services to you including fulfilling audit requirements, billing for services, and facilitating payments
• to analyse the financial documents and information you provide to our debt-management tools in order to identify your outstanding balances and repayment obligations and to generate personalised debt-repayment insights and suggested payoff plans for you, including by automated means using software algorithms and trusted third-party processing tools
• to carry out your instructions or to respond to any enquiries, complaints, comments or feedbacks that you have submit to us
• to protect or enforce our rights to recover any debt owing to us
• to compile information for analysis and in reports for relevant regulatory authorities
• to transfer or assign our rights, interests and obligations under any of your agreements with us
• to update, consolidate and improve the accuracy of our records
• to administer competitions, contests, offers, or promotions
• to produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual
• to conduct research for analytical purposes including but not limited to data mining and analysis of your transactions with us
• to assess financial and insurance risks
• to conduct surveys, questionnaire, and provide you with information from us or which we feel may interest you, where you have consented to be contacted for such purposes
• to engage in business transactions in respect of services to be offered and provided to you
• to comply with any legal or regulatory obligations under the applicable laws, regulations, guidelines or industry codes that applies to us
• for internal management of the services being provided to you
• to maintain records required for security, claims or other legal purposes
• to provide training for our staff
• to conduct marketing and information technology activities (for example, market research)
• to persons who have been identified as being you or your authorised representative(s) pursuant, for the purpose of the relevant transaction or enquiry
• to third parties with whom we have contracted to provide services to us (such as analysis on our behalf) for any of the purposes described above. Where we disclose your personal data to third parties we shall ensure that such data is used only to provide services to us
• for any other purposes that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities.

With Whom We Share Your Personal Data

As a part of providing you with our services and the management or operation of the same, we may be required or need to disclose information about you to the following third parties:

• federal or state government
• law enforcement agencies
• government agencies
• our regulator
• companies or organisations that act as our agents, contractors, service providers or professional consultant
• companies or organisations that assist us in processing and/or otherwise fulfilling transactions and providing you with services that you have requested
• our business associates and other parties for purposes that are related to the purpose of collecting and using your personal data
• other parties in respect of whom you have given your express or implied consent
• any credit reporting agencies or in the event of default, any debt collection agencies subject to the permitted law applicable to us.

Financial Documents You Upload to Our Debt Tools

Our debt-management tools allow you to upload financial documents such as credit card and bank statements so that we can analyse your debts and generate repayment insights for you. These documents are provided voluntarily and are used only for that purpose.

We do not share the documents or statements you upload with your banks, creditors, or other lenders, and we do not contact or negotiate with your creditors on your behalf. Your uploaded documents are transmitted over encrypted connections, stored on secure, access-controlled systems, and accessed only by authorised personnel and trusted service providers bound by confidentiality obligations. We retain them only for as long as necessary to provide the tools to you and as required by law, after which they are securely deleted or anonymised. You may request deletion of your uploaded documents at any time by emailing [email protected].

Where any document you upload incidentally contains sensitive personal data, you consent to our processing of that information for the purpose of providing the tools to you.

Artificial Intelligence and Automated Processing

MoneyMama is an AI assistant. The replies you receive when you chat with MoneyMama, in the MoneyMama mobile app or on WhatsApp, are generated by an artificial-intelligence model and are not written by a person. We disclose this in the app before your first message, and every reply can be reported from within the app if you believe it is wrong or harmful.

To generate those replies and to read the documents you upload, we share your messages, the financial information you have recorded with us, your first name, your country and currency, any receipt or statement images you send, and the transcribed text of any voice note (the recording itself is not kept), with AI service providers acting as our data processors. Some of the reminders and summaries the app sends you as notifications are also written by an AI model from the information you have recorded with us. These are established commercial AI companies, engaged under written contracts. They process your personal data on our instructions only, and we do not permit them to use it to train their models. We do not share your phone number, email address, date of birth or identity-document details with them. If you would like to know which providers we currently use, write to us at [email protected].

We obtain your explicit consent in the app before your first message reaches an AI service provider, and we record when that consent was given. MoneyMama is not a licensed financial adviser; what it produces is general financial education generated automatically, not regulated financial, legal or tax advice, and no decision producing legal effects concerning you is made solely by automated means.

If Personal Data Provided by You Is Incomplete

Where indicated in our application or registration forms manually or electronically, it is obligatory to provide your personal data to us to enable us to process your application for our services. Should you fail to provide a complete and obligatory personal data, we may not be able to process your application or provide you with our services.

Your Rights to Access and Correct Your Personal Data

We can assist you to access and correct your personal data held by us. Where you wish to have access to your personal data in our possession, or where you are of the opinion that such personal data held by us is inaccurate, incomplete, misleading or not up-to-date, you may make a request to us by emailing [email protected].

Children

Our services are not directed at anyone under 18, and we do not knowingly collect personal data from children. If you believe a child has given us personal data, write to [email protected] and we will delete it.

How Long We Will Keep Your Personal Data

We will retain your personal data in compliance with this Policy and/or the terms and conditions of your agreement(s) with Finlit Technologies Sdn. Bhd. for the duration of your relationship with us, for such period as may be necessary to protect the interests of Finlit Technologies Sdn. Bhd. and/or its customers as may be deemed necessary, where otherwise required by the law and/or where required by Finlit Technologies Sdn. Bhd. or its subsidiaries’ relevant policies.

How we protect and safeguard your personal data

We endeavour to take all reasonable steps to protect your personal data and keep your personal data secured. This includes following our security procedures (like checking your identity when you call us). Our site may link to other websites and we are not responsible for their data policies, procedures or their content.

Transfer of Your Personal Data Outside Malaysia

Any personal data, which you volunteer to us, will be treated with the highest standards of security strictly in accordance with the PDPA 2010. It may be necessary for us to transfer your personal data outside Malaysia if any of our service providers or business partners are involved in providing part of a service located in countries outside Malaysia. You consent to us transferring your personal data outside Malaysia in these instances. We shall take reasonable steps to ensure that any such service providers or business partners are contractually bound not to use your personal data for any reason other than to provide the services they are contracted by us to provide and to adequately safeguard your personal data.

Your Consent

By submitting your personal data, you consent to the use of that personal data as set out in this Policy. If we change our Policy, we will publish the amended version on this page. But you can email or write to us to ask for a copy. Continued use of the service will signify that you agree to any such changes.

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