Introduction

This privacy policy (“Privacy Policy”) of e-Check (“we”, “us”, “our”, “e-Check”, “website” or “mobile app”) are applicable to the use of any service by e-Check and shall be govern to the usage by any user of e-Check (“you”, “your” or “Customer”). References to e-Check shall include all subsequent variation and amendments made thereto.

By accessing e-Check, you hereby consent to the processing of your personal data (if so, provided by you) in accordance to the terms of our Privacy Policy by us and all persons involved in the provision of our services.

The “personal data” that you provide to us may include, inter alia, your name, contact details, address, email address, Computer Data (as defined hereinafter), national registration identification number, passport number, bank account information, income tax details, gender, nationality, personal preferences, involvement in legal proceedings including details of such legal proceeding, and all other related information necessary and incidental to our service that have been or may be collected, stored, used and possessed by us from time to time.

The list of personal data stated above is not exhaustive and may include other personal data depending on the nature of dealings or transaction. If needed, the request for these other personal data will be indicated on the relevant form that you may need to fill in, depending on the nature of the dealings or transactions, and for which you would need to give consent prior to us processing the same.

Please take time to read our Privacy Policy so that you understand your rights on the matter.

General Information

e-Check protects your personal information by complying with the operative legislation concerning personal data protection in Malaysia, being the Personal Data Protection Act 2010 (“The Act”), which came into effect on 15th November 2013. This privacy policy details how e-Check collects and uses your personal data, and informs you about the personal data protection measures we have put in place. When you get access to e-

Check, you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information only as described in this Privacy Policy.

Data That e-Check May Collect

Unless you are registered for online services from e-Check, you remain anonymous when you browse the website and/or mobile app. We do not collect personal information if you are only browsing this website or using the mobile app. In order to access our services, or process a transaction between you and a third party, we may request personal information such as your name, address, phone number, email address or country issued ID number, bank account information and other information that renders you identifiable. Please refer to the definition of “personal data” in the foregoing section.

e-Check collects personal information from you only when you choose to register for and/ or use our services, for example, inter alia, during the verification of the user on our platform. This personal information encompasses information communicated to us when you voluntarily complete an application form presented on our platform that makes it possible to identify you. By volunteering personal information, you undertake to communicate accurate information that does not prejudice the interest of any third parties.

How e-Check Use Your Data

Your personal data that e-Check collect allows us to process the necessary transaction in relation to our services that you may have opted for. Upon giving us consent, we may collect, use, disclose and otherwise process your Personal Data for the following purposes, depending on the nature of our relationship with you:

- To enable you to access and use e-Check’s services; and/or

- To personalize and improve aspects of our overall service to you and our other users, as well as carrying out research such as analyzing market trends and customer demographics; and or

- To communicate with you, in order to verify the personal information provided, or to request any additional information that is vital to fulfilling the service you have applied for; and/or

- To send you information about products and services which we think may be of interest to you; and/or

- To respond to your queries and requests; and responding to complaints; and/or

- For managing the infrastructure and our business operations and complying with our internal policies and procedures; and/or

- For verifying your identity; and/or

- For protecting and enforcing our contractual and legal rights and obligations; and/or

- Complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/ or

- To optimize and customize your user experience with our website and chatbot; and/or

- To process your application for online subscription services; and/or

- To maintain your account with us; and/or

- To verify and process your personal details and payments in relation to provision of online subscription service to you; and/or

- To provide you with the services which you have signed up for; and/or

- To provide you the products which you have paid for; and/or

- To keep you posted on e-Check’s latest services or product announcements and upcoming events; and/or

- Resolving complaints and handling requests and enquiries; and/or

- Conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and/or

- To send important notices, emails, letters or short messaging service (SMS), like communications about purchases and changes to e-Check’s terms, conditions, and policies; and/or

- To share your personal data with third party providers for the purposes of (but not limited to) fulfillment of customer orders, processing and delivery of financial products to you; and/or

- For any of the purposes relating to the above.

All provision of personal data is on a voluntary basis. However, if you decide not to provide us with any of your personal data, we may not be able to provide you with the products / services requested, the same which may, under certain circumstances, affect our business relationship with you.

Impact Resulting from Failure to Supply Data

All provision of personal data is on a voluntary basis. However, failure to supply personal data may affect our ability to deliver optimised user experience service to our registered users. In addition, failure to provide certain essential personal data may result in us being unable to provide you with the services and/or products that you have opted for.

Disclosure of Personal Data

Personal data provided to us will generally be kept confidential but you hereby consent and authorize us to provide or disclose your Personal Data to the following categories of parties:

- Any person or authority to whom we are compelled or required to do so under law, court order or in response to a competent or government agency;

- Our business partners and online affiliates that provide the services that you have opted for or related services or products in connection with our website and/or mobile app including, but not limited to market research firms, third party marketing entities, entities engaged in the financial related services, telecommunications, technology and car industry;

- members of our Group companies and their affiliates;

- government agencies and industry regulators;

- our auditors, consultants, accountants, lawyers or other financial or professional advisers; and

- such sub-contractors or third-party service or product providers as we may determine to be necessary or appropriate.

Retention of Personal Data:

Collected information is retained for the period taken to fulfill the many different purposes outlined in this Privacy Policy unless a longer retention period is permitted or required by law. During this period, e-Check is committed to all reasonable efforts and practical steps to ensure that collected data is protected against any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. We undertake to protect the confidentiality of your data to the purposes set out in this policy, and therefore to ensure your data privacy.

The purpose of such collection and retention and otherwise processing of personal data is towards e-Check assisting you in your use of the platform. In order to assist you with other products/services in the future, we will retain your data even after the completion of the transaction between e-Check and yourself. By submitting your personal data on our platform, you expressly consent for the retention of the same. If you do not wish to have your personal data on our website and/or mobile app, you may opt out by contacting our Privacy Officer indicated in this Privacy Policy.

Accessing Data and Ensuring Accuracy:

e-Check takes all reasonable steps to ensure that your information is accurate, complete, not misleading and kept up-to-date, consistent with the purposes for which the information was collected.

Please contact us via the contact details provided in this Privacy Policy if you would like to access or correct personal information that is inaccurate, incomplete, misleading or not up-to- date. We will use reasonable efforts to accommodate requests for access and information changes. Similarly, please contact us should you wish to withdraw consent for the use of your personal information.

Keeping You Informed:

You agree that we shall be entitled to advise you via email, post, telephone or by text of products, services and other offers we think may interest you.

Whenever you provide us with personal information, you shall have the option to consent to us and others using and sharing your information for marketing purposes. Unless you tell us otherwise, you are deemed to consent to such uses.

Any electronic marketing communications we send you will include clear and concise instructions to follow should you wish to unsubscribe at any time.

Should you:

- no longer wish to be contacted by us;

- wish to obtain further information on how to limit the processing of your personal data;

- wish to access or correct your personal data;

- have any further query; or

- wish to make a complaint in respect of your personal data,

You can advise us at any time by contacting e-Check’s data privacy officer with the following details:

- Address:

- E-Response Alert Sdn Bhd

- D-2-12, Block D, Ritze Perdana,

- Jalan PJU 8/2, Damansara Perdana,

- Selangor, 47820 Petaling Jaya,

- Email: inquiry@e-response.biz

- Tel: +603-7726 8343

Third Party Providers and Data Privacy

If you decide to enter into a contract with a third party provider through e-Check, the information you have provided to us together with any further information requested by, and supplied by you or us to the third party provider will be held by the provider for the purposes set out in that provider’s privacy policy. Therefore, you are strongly advised to read your chosen provider’s privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the contract. We shall bear no responsibility or liability for the uses to which a provider puts your personal information.

Data Transfer and Sharing

Where we consider it necessary or appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your personal data to another member of our group companies or third party service or product providers within or outside the country in which we are established, under conditions of confidentiality and similar levels of security safeguards.

Collection of Computer Data Not Necessarily Personal Data

When you visit e-Check, our servers will automatically record information that your browser sends whenever you visit a website. This information may include:

- Your device’s IP address

- Browser type

- Cookies

- GTM Event Tag

- Webpage you were visiting before you came to our website

- The pages within e-Check that you visit

- The time spent on those pages, products and information searched for on our site, access times and dates, and other statistics

(Collectively known as “Computer Data”)

This information may be collected for analysis and evaluation in order to help us improve our website and products we provide. Said information may be used in association with any other personal data.

Visiting Our Platform from Outside Malaysia

This Privacy Policy is intended to cover collection of information on website & mobile app from residents of Malaysia. If you are visiting our website & mobile app from outside Malaysia, please be aware that your information may be transferred to, stored and processed where our servers are located. The data protection and other laws of Malaysia might not be as comprehensive as those in your country.

Conflict

The terms in this English language Privacy Policy shall prevail should there be a conflict between the development of other language policies.