Privacy Policy

ITMAX SYSTEM BERHAD’S PERSONAL DATA NOTICE

Personal Data Protection Act 2010

Date of last update: 20th Aug 2024

This written notice serves to inform you that your personal data is being processed by or on behalf of ITMAX System Berhad (hereinafter referred to as “ISB”, “us”, “our” or “ours”). For the purpose of this written notice, the terms “personal data” and “processing” shall have the meaning assigned to them in the Personal Data Protection Act 2010 (hereinafter referred to as the “PDPA”).

During your course of dealing with us, we will collect and process your personal data for several purposes, including, to communicate with you, provide products and/or services to you, respond to your enquiries or complaints, provide you with information and/or updates on products, services and/or promotions offered by ISB and selected third parties, and other purposes required to operate and maintain our business as set out in this Personal Data Privacy Policy (collectively referred to as “Purposes”).

Description of Your Personal Data

ISB will only collect personal information of users and/or customers to the extent necessary for the operation and provision of services to our users and/or customers and for other purposes directly related to our operation and provision of the services.

Your personal data that are collected and processed by ISB includes:

• Your personal details and contact details which you have provided to us including your name, date of birth, NRIC or passport number (and where necessary, copies of the same), e-mail address, mobile number and where applicable, bank account details and credit/debit card details;
• Information about you which are collected by our technology, including all payment and credit top-up transaction details from our e-Payment and credit top-up agents, electronic/mobile communications with ISB, our vendors and other related third parties;
• Information collected from your use of our website, mobile application or any other platforms operated by us (including information such as the website from which you visit ISB platforms, the pages and content which you view, the date and duration of your visit, cookies to track usage patterns from the analytics tools such as Google Analytics and others);
• Feedback information which you have provided via an official feedback form or otherwise gathered from any of our platforms;
• Information provided by you during on-ground or digital promotions, tie-ups, contests, and any other marketing activities that may be carried out by ISB or its trusted partners. Information collected from third parties or other permissible or authorised sources, such as where you have given your consent to third parties’ websites (e.g. public or permitted directories) to disclose to us information relating to you, and personal data collected through banks, financial institutions and/or credit reporting agencies.

Purposes for the Processing of Your Personal Data

ISB may process your personal data collected from you or from any of the class of third parties stated in this Personal Data Privacy Policy, for any one or more of the following purposes:

• To register and operate your account with us.
• To assess, process and provide our products and/or services to you.
• To facilitate and process payments made through our platforms and to keep records of the same for auditing, anti-money laundering prevention actions, and other legal purposes.
• To administer and process any payments related to products and/or services requested by you.
• To conduct credit reference checks and to establish your creditworthiness.
• To verify your identity and carry out due diligence or other monitoring or screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or that may have been put in place by us.
• To communicate with you and deliver information that is requested by you and/or, in some cases, is targeted based on your usage and interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use of ISB’s platforms.
• To personalise and improve your user experience with our platforms.
• To communicate with you and to provide, maintain and improve customer support and relationship, including responding to your enquiries or complaints or resolving any issues and disputes which may arise in connection with any of your dealings with us.
• To conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services.
• To provide you with information about the activities, products, services, events and programmes that may be organized, managed, facilitated, provided, sponsored, and/or participated by us, our subsidiaries, partners or sponsors.
• For our storage, hosting back-up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Malaysia.
• To notify you about benefits, changes to the features, promotions, alerts, to provide you with newsletters, updates, promotional materials, and special privileges, and to send you festive greetings and tourism-related content.
• To enable ISB’s customer loyalty programmes, where applicable.
• To enable us to monitor and improve our services to you, including for the purpose of staff training, quality assurance, maintenance, and improvement of our platforms and related technology.
• To comply with any legal or regulatory requirements applicable to ISB and to make disclosures under the requirements of any law, regulation, direction, court order, by-law, guideline, circular, or code applicable to ISB; and/or for any other reasonable purposes required to operate, maintain and better manage our business and your relationship with us.

Source of Your Personal Data

Your personal data is collected directly from you when you:

• Interact and communicate with ISB and/or our subsidiaries, partners, or sponsors at any events or activities related to us.
• Communicate with ISB, for example, when you purchase credit top-ups and monthly passes via ISB channels, or when you contact ISB for any enquiries, including by getting in touch with ISB’s customer service through any available ISB channels.
• Register or subscribe for a specific service or publication from ISB.
• Participate in any of our surveys, polls, or other similar activities conducted to improve the content of ISB’s website/ISB Mobile App, or used for ISB’s marketing purposes.
• Enter or participate in any competitions, contests, or loyalty programmes organized by ISB and/or any of its subsidiaries, partners, or sponsors.
• Register your interest and/or request information through our platforms or any other available channels.
• Respond to any marketing materials that ISB sends out.
• Visit or browse ISB’s platforms.
• Lodge a complaint with ISB or any of our authorised third parties.
• Provide feedback to ISB.

Other than the personal data obtained from you directly as stated above, ISB may also obtain your personal data from third parties (as further explained in "Description of Your Personal Data" and "Purposes for the Processing of Your Personal Data" above).

Your Rights

You have the following rights in relation to your Personal Data:

• To make a data request in writing to ISB for information on your personal data that is being processed by or on behalf of ISB (Section 30(2) of PDPA).
• To correct any of your personal data which is inaccurate, incomplete, misleading, or not up-to-date at any time.
• To limit the processing of your personal data, including the personal data relating to other persons who may be identified from your personal data (Section 7(1)(f) of PDPA).
• To unsubscribe from our marketing materials and/or correspondence by clicking the unsubscribe link contained in the emails and/or newsletters ISB sends to you and following the instructions therein.
• To request that your personal data be removed from ISB’s database in writing by contacting ISB via email at support@malaysiatrulyasia.my.

If you have any requests in relation to the abovementioned rights or any inquiries or complaints in respect to your personal data, please write to us at support@malaysiatrulyasia.my.

Please note, however, that ISB may refuse to comply with your request under limited circumstances as specified within the PDPA. If ISB refuses to comply with such a request, we will inform you of our refusal and the reason(s) for our refusal as soon as possible, or in any case, within the timeline outlined by the PDPA.

Class of Third Parties to Whom ISB May Disclose Your Personal Data

The following is a list of the class of persons to whom ISB may disclose your personal data:

• ISB’s group of companies (including our direct and indirect shareholders, and our parent, holding, subsidiaries, related, and/or associated companies).
• Our professional advisers, vendors, suppliers, agents, contractors, service providers, business partners, customers, insurance companies, banks, and/or financial institutions.
• Successors-in-title to us.
• Parties involved in any corporate exercise (e.g., proposed or actual mergers and/or acquisitions, joint ventures, funding exercises, asset sales, or other matters of such nature that relate to us).
• Any governmental agencies, regulatory authorities, local authorities, municipal councils, and/or statutory bodies.
• Whether within or outside Malaysia, and where necessary, to any party who undertakes to keep your personal data confidential in carrying out the purposes mentioned above or to persons to whom we are compelled or required under the law to make such disclosures to.

Your Obligation

• We would require you to provide to us with your complete, updated, and accurate personal data, and your failure to do the same may result in ISB not being able to provide its full services to you as outlined by the Purposes.
• You will take reasonable steps to ensure that your personal data is accurate, complete, not misleading, and kept updated.

Security of Your Personal Data

We are committed to ensuring that your personal data is stored securely. We will take practical steps to protect your personal data from any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration, or destruction, including but not limited to applying such protections through the use of procedural and technical safeguards such as encryption, “firewalls” and secure socket layers. If any security breach has come to your attention with regards to your use of our services, please let us know as soon as possible.

Notwithstanding the same, we admit that perfect security does not exist on the internet and as such ISB is unable to provide absolute assurance that your personal data that you provide to ISB will be secure at all times. ISB disclaims responsibility for any breach arising from unauthorized access to or theft of your personal data which are not attributed to our negligence to take reasonable precaution.

Retention of Your Personal Data

ISB will only keep your personal data for the duration that is necessary to carry out the Purpose for which your personal data was collected and also for the other Purposes set out in this Personal Data Privacy Notice.

Amendment to this Personal Data Privacy Policy

ISB reserves the right to amend this Privacy Policy and Personal Data Notice at any time by posting an amended Personal Data Privacy Notice containing such amendments on ISB’s website/ISB Mobile App or by any other mode ISB deems appropriate.

Users under the age of 18

ISB reserves the right to amend this Privacy Policy and Personal Data Notice at any time by posting an amended Personal Data Privacy Notice containing such amendments on ISB’s website/ISB Mobile App or by any other mode ISB deems appropriate.

Inconsistency or Conflict

In the event of any inconsistency or conflict between the English language version and the Bahasa Malaysia version, the English language version shall prevail.

Links to Other Websites

When you use a link from ISB’s website or ISB’s Mobile App to another third-party website, this Privacy Policy is no longer in effect. Once you have used such link, ISB does not have any control over that other third-party website and ISB cannot and shall not be liable or responsible for the protection and privacy of any personal data which you provided whilst visiting such website(s). Your browsing of and interaction on any other third-party website(s) will be subject to that websites’ own rules and policies.

Data Deletion Process

Step-by-Step Guide to Request Data Deletion

1. Emailing Support: Initiate the process by sending an email to support@malaysiatrulyasia.my or by filling up this form.
2. Information to Include: In the email, clearly state your request for data deletion. Provide your username/name, email address used to access Malaysiatrulyasia Apps, and any other relevant details to help us locate your account.
3. Confirmation and Follow-up: After receiving your email, our support team will contact you for confirmation and any additional information required.

Data Deletion Process

Upon confirming your request, we will proceed with the deletion of your personal data, which includes:

• Email Address
• Username
• Full Name
• ID Number (UUID)
• Password: For security, we will immediately invalidate your password.
• Passport Details
• Location Accessed: Records of places you have visited will be removed.