Privacy Policy

Payment2me is a corporation organized and existing in the Malaysia (“Payment2me”, “we”, “us” or “our”) takes your privacy very solemnly.

This privacy policy (this “Privacy Policy”) describes what information we collect from you, the purposes for which we collect and process it, how we use it, who we share it with, how long we retain it, and your rights in relation to it. You should read this Privacy Policy in its entirety.

This Privacy Policy applies in connection with your use of the Payment2me Android mobile application found here (the “Payment2me App”) and your use of our services through the Payment2me App or otherwise. It does not apply to your use of the Company’s website, found at www.payment2me.com (the “Website”). Please see here for the privacy policy applicable to your use of our website.

1.What data does Payment2me collect and process?

Identification data (e.g., first name, surname, date and place of birth);
Data provided by you through your loan application (e.g., information about your income or employment, your proposed use of your loan proceeds, customer-provided information about your mobile device);
Contact details (e.g., address, phone number, alternate phone number, email address)
Government-issued identification data and documents (e.g., ID card, Driver’s License, Passport);
Mobile device data (e.g., SIM, IMEI, or other device identifiers, type of device, device operating system, device settings, user account information for your mobile device or Google PlayStore account, the name and network information of your mobile network provider, device specifications (such as screen size, resolution, etc.), information about network proximity);
Location data (e.g., mobile device location, time zone setting);
Transaction data and financial information (e.g., loans, transfers, payments, loan requests, tax information);
Phone data (e.g., contact lists, SMS logs, types and nature of mobile applications found on your mobile device);
Telecommunications usage data ( SMS records, subscription data, payment details, applications and usage data, telco score);
Payment2me App usage (e.g., traffic (volume) data, information about your usage of the Payment2me App);
Data related to your communications with Payment2me (e.g., your communications with Payment2me via in-app chat, email, telephone or other channels);
and Certain third party data (e.g., information provided to or from credit reference agencies or bureaus, external collections agencies, mobile network providers). (collectively, your “Information”)

Payment2me may collect your Information from

You, when download the Payment2me App and/or indicate that you want to apply for a loan;
Your other interactions with us, including Information you may voluntarily share with our customer support team or other Payment2me employees or agents;
Your mobile device (e.g., mobile device data, location data, transaction data, Payment2me App usage and/or phone data as more fully described above)
Third parties and other publicly available sources, with your consent, when necessary (e.g., we may receive Information from financial rails (or other disbursement channel vendors) or other business partners that may assist us in providing services to you).

Collection and processing of your Information by Payment2me is necessary for the provision of Payment2me’s products and services and/or to comply with applicable legal and regulatory requirements to which you and/or Payment2me is subject. Aside from such cases, we do not collect Information without your specific prior consent.

2.What are the purposes for which your Information is processed? How does Payment2me use your Information?

To assess your eligibility to use our products or services (including, but not limited to, by assessing yourncreditworthiness, determining whether you can afford a product or service you requested and/or determining whether you are eligible for additional benefits of an existing product);
To service your loan with Payment2me (including, but not limited to, by processing your transactions and processing disbursement of your loan and collecting repayment of your loan);
To verify your identity and/or other information you have provided to us;
To detect, combat and prevent fraud, attempted fraud, money laundering and/or other illegal uses of our services;
To analyze customer behavior;
To administer out systems, maintain service quality and compile general usage statistics;
To analyze and improve our services;
To troubleshoot any problems you or other customers encounter with Payment2me’s services;
To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer” and/or anti-money laundering;
To the extent you have not objected to the use of your information for direct marketing purposes after proper notification, to send you marketing or advertising notices or other promotional offers;
To provide service updates;
To provide staff training (where we may monitor or record customer interactions);
To interface with credit reference or fraud prevention agencies;
To provide customer service or support;
To contact you by telephone using autodialed or prerecorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy.

We process your Information for the purposes set out above on the following grounds:

A. In connection with the nature of our business in (1) providing you with credit and/or other financial or technological products or services, (2) operating our business, (3) marketing our products and services to you and others and (4) administering our systems and keeping our records up to date;

B. To carry out our obligations to you as a result of any contracts or agreements entered into between you and us (i.e., where necessary for the adequate performance of our contract with you and/or to take steps requested by you prior to entering into a contract with you); To carry out our legal obligations under applicable law; and With your prior consent.

3. Who do we share your Information with?

General

Payment2me shall not disclose any Information containing personal data (as defined under applicable law) to any third parties, unless it is necessary and/or appropriate in order to provide Payment2me’s products or services, provided that, we may share limited personal data (as defined under applicable law) with select partners for the purpose of research and development. Whenever practically feasible, Payment2me will only share your Information with third parties in an anonymized format.

You agree that we may, as necessary and/or appropriate for the purposes provided in section 2, transfer and disclose your information to other third parties to the extent (1) we have a duty to disclose or share your information in order to comply with any legal obligation, (2) necessary or appropriate to enforce or apply any agreement with you, and/or (3) necessary or appropriate to protect the rights or safety of Payment2me, the Payment2me Group and/or our customers.

The above parties may also process or disclose your information for the purposes set forth in Section 2, so long as such processing or disclosure is in compliance with this Privacy Policy.

Further, Payment2me may also share your information with law enforcement or other government agencies pursuant to a formal request, subpoena, court order, or similar legal procedure, or when we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our agreements with you.

Referrals

To promote its products and services, Payment2me administers and services a referral program (“Payment2me Referral Program”) for its current and future customers. If you choose to accept a referral from another Payment2me customer and accept a Payment2me loan in connection with that referral, Payment2me will provide a bonus to the customer who refers you upon your successful repayment of your Payment2me loan.

If you choose to participate in the Payment2me Referral Program as a referee, you specifically consent to the sharing of such anonymized information about your repayment status by accepting the referral, clicking on the embedded referral link and subsequently applying for and accepting a Payment2me loan through such referral.

Sharing of your Information in connection with the Payment2me Referral Program shall be limited to the information described above and shall remain anonymized – Payment2me will never share identifiable or personalized data about your repayment status (or any other personal data (as defined under applicable law) with any other customer or user or Payment2me. More information on the Payment2me Referral Program is available within the Payment2me App.

4. For how long will we retain your Information?

Your Information will be stored or retained by Payment2me and its transferees only for so long as necessary for the purposes listed in this Private Policy, and for a reasonable time thereafter for the delivery of our products and completion of our services.

We may also retain your Information (i) as long as necessary to comply with any legal obligation; (ii) whenever such is authorized under the law; and (iii) for the establishment of legal defenses. Information that is no longer needed for the purpose(s) for which it was collected shall be deleted or anonymized except as necessary to comply with legal obligations.

However, it should be noted that sensitive data, including your SMS, call logs, contact list, and installed application list, will only be analyzed in the cache by Payment2me, and will be automatically and permanently deleted from the cache after obtaining the necessary conclusions, without being persistently stored.

5. Where do we process, store or transfer your information?

We may transfer your Information outside of the Malaysia, either to the United States, or Singapore, or China and/or to the extent we provide prior notice to you, to jurisdictions that may have data protection laws that are less stringent than those of the Malaysia. When we do so, we will ensure that adequate safeguards are in place in accordance with applicable law and/or the Malaysia’ data protection requirements. The safeguards we will use will depend on the circumstances and the party to whom we transfer your Information

6. Automated decisions and profiling

We may make certain decisions in relation to our provision of our products and services to you by using automated decision-making processes, without human involvement.

7. Lending decisions

When you apply for a loan, we shall use automated processing to decide whether to commence with the transaction or otherwise based on your eligibility for our products and services. This automated processing enables us to provide rapid, responsive and tailored credit services to customers who may not have credit histories, prior bank or other financial data or income from formal sources.

Our credit and underwriting models utilize machine-learning technology to process your Information and assess your credit-worthiness. The associated processing of your Information is automated and little to no human intervention is involved. Using such automated processes to assess your creditworthiness means we may automatically decide that you may be ineligible for a loan or ineligible for a loan of a particular amount or tenure.

Our credit and underwriting models are regularly tested to ensure they remain fair, accurate and unbiased.

8. Detecting fraud

Payment2me also utilizes automated processes to detect, combat and prevent fraud. Our fraud models may automatically decide that a certain individual poses a fraud or money laundering risk (e.g., if our processing reveals information or behavior consistent with money laundering or known fraudulent activity, if the activity is inconsistent with prior activity on our platform or if an individual appears to be hiding their true identity). If our fraud models determine that processing of a transaction or approving a certain individual creates a risk of fraud, that individual’s access may be suspended or refused.

9. Your rights in relation to automated decision-making

In the event that your loan application is denied or your loan is declined, or you are found ineligible for other or associated products or services as a result of an automated credit, underwriting or fraud decision, you may request that said decision be reviewed through our CS Dept.

Your rights as a data subject

You may contact us to exercise your rights through our CS Dept.

Rights to be informed

We shall provide you with the necessary information as to how we collect your Information, how we use the same (and our legal basis for doing so), who we share your Information with, where we obtained your Information and your rights as a data subject. This information is provided within the Payment2me App and in this Privacy Policy.

Right to access

You may ask for a copy of the personal data (as defined under applicable law) in our possession (and your Information related to such personal data), unless providing some or all of it would adversely affect the rights and freedoms of others or applicable law requires that we do not comply with your request.

Right to rectification

You may ask us to correct any Information which you believe to be inaccurate. We will promptly update such information. In connection with your request, you may be required to provide supporting evidence or other documentation so that we may verify the accuracy of the thereof.

Right to erasure (“right to be forgotten”)、

You may ask us to delete your personal data (as defined under applicable law) from our system:

If you believe it is no longer necessary for us to retain such personal data;
If you do not believe we have legitimate ground for processing it;
If you think we are using such personal data unlawfully; and/or
If you think applicable law requires that we do so.
Right to restrict or object to processing.

Where the processing of your personal data is based on your consent or our legitimate interest, you may ask us to stop using your personal data (as defined under applicable law):

if you think such personal data is inaccurate;
if you think it’s illegal for us to use such personal data;
if you don’t want us to destroy such personal data because you need it for legal proceedings;
if you’ve informed us that we don’t have a legitimate reason for using it and we’re considering your request.
Right to data portability

If we’re using your information on the basis of your consent or because we need it to carry out our contractual obligations to you, you can ask us to give you your personal data (as defined under applicable law) in a structured, commonly-used and machine-readable format or have it transmitted to another data controller.

Right to damages

You have a right to be indemnified if you suffered damages due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, considering any violation of your rights and right to as data subject.

Right to file a complaint

You have the right to file a complaint with the appropriate government agencies for any violation of your rights as a data subject.

Please note that there may be occasions when you wish to exercise your rights and we are unable to agree to your request (e.g., because we have compelling legitimate grounds for using or processing your information or because we need to retain your information to comply with a legal obligation).

Advertising and Marketing

You may opt out from receiving advertising, marketing or promotional messaging by contacting us and making such request through CS Dept. and we will remove you from such communication lists.

10. Consequences of not providing us with your Information

You are not required to provide us with your Information or any associated personal data (as defined under applicable) and you may withdraw your consent from the use or processing of such Information or personal data. However, we likewise reserve the right to you are your application or terminate our relationship with you, due to failure to conduct a sufficiency and exhaustive evaluation on our part and/or as permitted under applicable law/s. Further, to the extent we have a legitimate interest in retaining your Information and/or associated personal data (as defined under applicable law), we may do so. For example, if you have requested that we erase your Information or associated personal data (as defined under applicable law), but you have not repaid your loan with Payment2me, we may retain your Information or associated personal data (as defined under applicable law), in order to continue collection efforts. We are also required to retain your information for a period of at least five (5) years in compliance with anti-money laundering and terrorism financing prevention regulations, not with standing requests for deletion.

Consent and Authorization

By downloading the Payment2me App, you:

accept the terms of this Privacy Policy;
give Payment2me consent to collect, use, share, or otherwise process your Information, which may include personal information, sensitive personal information or privileged information (in each case, as defined under
applicable law), as outlined in this Privacy Policy;
certify that all Information you have provided and will provide to Payment2me is true and correct to the best of your knowledge;
authorize Payment2me to verify/investigate the accuracy of your Information; and
acknowledge that Payment2me may be required to disclose your Information to governmental body, in compliance with its legal obligations and in accordance with principle of proportionality.

General

If you have questions about this PRIVACY POLICY or about your rights as a Data Subject, you can contact our Data Protection Officer at: [email protected]

To improve and continue our services to you, this Privacy Policy may be updated from time to time. We will notify you prior to any updates to this Privacy Policy, either within the Payment2me App or by email.