Objective and Application
Moby Money Sdn. Bhd, its parent company, its subsidiaries and affiliates (“Moby Money”, “Us”, “We”) is the owner and operator of MOBY (MOBY website) any subdomain thereof (“Website”) or related mobile application (“Apps”), related databases and supporting software which you may access in the course of engaging with us (collectively referred to as “Platforms”).
We place significant emphasis on your needs, particularly in terms of providing affordable payment plans and ensuring a seamless online shopping experience. To achieve this, we may collect various types of personal information associated with you or that can be used to identify you (“Personal Data“) to tailor our services to better meet your requirements. We understand that you may have legitimate concerns regarding the usage and processing of your Personal Data. However, we want to assure you that safeguarding the privacy and security of your Personal Data is of the utmost importance to us.
Section I of this Privacy Policy is curated to ensure you understand how we collect, disclose, use, process your Personal Data and how we are committed to protecting the security and privacy of your Personal Data in our custody in accordance with the Personal Data Protection Act 2010 and any other applicable data protection laws and regulations (hereinafter referred to as (“Applicable Data Protection Laws”). Section II of this Privacy Policy will inform you of your data privacy rights and how you can be in control of your Personal Data.
Please note that this Privacy Policy shall apply automatically on the account of you using our Platforms and Services. Your consent for the processing and disclosure of your personal data is procured when you tick to accept the Terms of Service and this Privacy Policy or when you create a MOBY account with us.
To make an informed and conscious decision before using our Platforms, products and Services, we highly encourage you to study and understand this Privacy Policy.
SECTION I: PROCESSING OF PERSONAL DATA
A. What Is Personal Data?
For your better understanding, we have broken down several categories of Personal Data as follows:-
Identity Information
Name, date of birth, age, gender, identification or passport number, identification documents such as identification card, passport, driving licence, social medial handle, biometric verification such as fingerprint,
facial image, voice recording, proof of address such as utility bills and any other documents capable of corroborating your identity.
Contact Information
Contact details such as residential address, shipping and billing address, email address, phone number, proof of address such as utility bills.
Purchase Information
Bank account number, credit card number, debit card number, shopping items, wishlist items, purchase history, browsing behaviour, product reviews, purchase behaviour such as frequency of purchase, time of purchase and type of purchase.
Credit Profile
Payment behaviour, default in payment, outstanding amount, income amount, proof of income such as bank statement and other income statement, credit information obtained from credit reports which includes outstanding payment, number of loans, credit score, employment documents such as latest EPF Statement, latest pay slip and latest business card.
Sensitive Information
Personal Data may also constitute another class information that are highly sensitive such as data related to your health, religious, political views or other similar beliefs. Due to the nature of our products and Services, we typically may not need this class of Personal Data. However if collection and processing of Sensitive Information becomes reasonably necessary to provide our Services, we will obtain your explicit consent.
Others
IP address, server logs, login and logout details, device information, geographical location, marketing and communications data (preferred mode of communication, history of communications) other information you provide to us voluntarily such as, feedback, recommendations
B. How and When Do We Collect Your Personal Data?
We may collect your Personal Data in the process of providing our Services or in the course of our transaction or engagement with you.
Here is how and when we collect your Personal Data:
- Your use of our Platforms i.e when you browse through the Website and Apps and when you accept the Cookies on your device.
- Your interaction with us on Social Media such as Facebook, LinkedIn, Instagram, Twitter etc by liking, commenting and sharing our posts and messaging us through the available direct messaging feature.
- Your direct engagement with us i.e when you engage with our customer support team or our official representatives via live chats, telephone calls, emails, face-to-face meetings or during events and roadshows. Filling out questionnaire and surveys, participation in our promotions or public campaigns shall also be deemed as direct engagement.
- From publicly available sites or directories
- From official sources in the financial service industry, for example any bureaus or agencies under Bank Negara Malaysia, Securities Commission or other regulatory authorities, the Association of Islamic Banks Malaysia
- From third party affiliates i.e when you use our Services via services provided by our affiliate online merchants, partnering businesses, financial institutions, third party service credit providers for example private employment debt collection agencies or via their respective platforms.
- From registered Credit Reporting Agencies or entities providing credit background verification services i.e when we perform credit risk assessment on you to determine the eligibility for our Services.
- Your voluntary submission of your Personal Data for any reason.
| Purpose | Recipient of Personal Data | Type of Personal Data Most Likely Disclosed |
| 1. Identification & Account | ||
| (a) To verify your identity and to prevent identity theft (b) Performance of Know Your Customer (KYC) checks (c) Creation of your online account in our Platforms | • Moby Fintech’s relevant employees • Third party agents who conducts the (KYC) checks. | Identity Information, Contact Information, Others |
| 2. Identification & Account | ||
| (a) To respond to your enquiry, complaints, requests (b) To provide customer support and to learn about your level of satisfaction with our Services (c) To diagnose problems with our server, database and to administer our Platforms | • Moby Fintech’s customer support, data protection officer, IT team • Third Party IT Service Providers | Identity Information, Contact Information, Purchase Information, Others |
| 3. Credit Risk Assessment | ||
| (a) To ascertain your credit worthiness and background to ensure that you are capable of paying the agreed instalments. We usually do this by extracting a credit report from a registered Credit Reporting Agency and reviewing your past credit behaviour and credit score (b) To determine the eligible spending limit by reviewing your sources of income and proof of employment and by conducting other assessments, checks and verifications. (c) To perform alternative data modelling based on your payment and purchase behaviour to enhance our credit risk assessment process | • Moby Fintech’s credit team • Registered Credit • Reporting Agencies • Banks and Financial Institutions • Insurance providers • Credit Card companies • Securities and Investment Services providers | Identity Information, Contact Information, Purchase Information, Credit Profile |
| 4. Security | ||
| (a) to store, host, back up (whether for disaster recovery or otherwise); (b)to notify you of any system maintenance, suspected security breach | • Moby Fintech’s customer support, data protection officer, IT team • Third Party IT Service Providers • Governmental & Regulatory Authorities | Identity Information, Contact Information, Purchase Information, Credit Profile, Sensitive Information, Others. |
| 5. Compliance | ||
| (a) To monitor compliance with internal risk controls, our Terms of Service, and usage of Platforms. (b) To conduct audit, business reporting, quality control (c) To comply with directions provided by regulatory or statutory authority such as example Bank Negara Malaysia Securities Commission and Bursa Malaysia or parties as mandated by the Applicable Laws (“Govermental & Regulatory Authorities”). (d) To assist Governmental & Regulatory Authorities with law enforcement, judicial proceedings, and investigations To comply with any requirement of applicable laws, order of any court or tribunal | • Moby Fintech’s relevant employees • Professional advisors • Auditors • Consultants • Affiliate online merchants • Partnering businesses. • Governmental & Regulatory Authorities | Identity Information, Contact Information, Purchase Information, Credit Profile, Sensitive Information, Others. |
| 6. Product and Platform Development | ||
| (a) To conduct surveys for the development of our products and Services (b) To improve and personalise user experience when you visit our Platforms; (c) To perform data and trend, research, survey on your usage of our Platforms and our Services to improve our Services and enhance user experience (d) To produce statistics, reports and market analysis | • Moby Fintech’s relevant employees • Third Party IT service providers • Data Analytics Service Providers • Investors | Identity Information, Contact Information, Purchase Information, Others |
| 7. Marketing | ||
| (a) To send you materials such as newsletters alerts updates, mailers promotional materials special privileges festive greetings from us our partners sponsors or advertisers; (b) To share your name and contact number with our partners advertisers event companies or sponsors who may communicate with you for the purpose of marketing. (c) To notify and invite you to events or activities organised by us our partners sponsors or advertisers. (d) To provide you with information on marketing campaigns, promotions that we or our business partners believe would be of interest to you; (e) To process your registration to participate in or attend an event or activity and to communicate with you regarding your attendance at the event or activity (f) To collect demographics, outreach of our campaigns, promotions and events (g) To display your feedback, recommendations on our Platforms or disclose the same with Affliate online merchants, any third party companies and businesses who are interested in our services and products | • Moby Fintech’s customer support team third party agents who communicate with you •Affiliate online merchants • Partnering businesses. • Advertising companies • Funding managers • Sponsors • Event organisers | Identity Information, Contact Information, Purchase Information, Others |
| 8. Fraud, Money Laundering, Bribery & Violations | ||
| (a) To investigate or report any suspected crime such as money laundering, fraud and other prohibited activities (b) To track suspicious behaviour by analysing payment behaviour, rejected credit cards, multiple login failures etc (c) To investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or Platforms | • Moby Fintech’s relevant employees • Information Technology (IT) service providers • Consultants • Regulators Statutory Authority • Government Authorities •Police and Enforcement | Identity Information, Contact Information, Purchase Information, Credit Profile, Others |
| 9. Enforcement of Our Rights | ||
| (a) To enforce our legal or contractual rights under Terms of Service, any end user licence agreement including to recover any debt owing by you to us by initiating legal proceedings or by engaging debt collection agencies. (b) To submit any information pertaining to your default in payments or payment behaviour to any registered credit bureaus which will be reflected on your credit reports. | • Moby Fintech’s relevant employees • Professional advisors • Auditors • Consultants • Debt Collection Company • Third parties in connection with the restructuring of any facility granted to your sale of debts or assets or acquisitions by us • Registered Credit Reporting Agencies | Identity Information, Contact Information, Purchase Information, Credit Profile, Others |
| 10. Operations | ||
| (a) Payment collection – to collect instalment payment or any other outstanding amount owed to us (b) to process all transaction with us or your transactions or communications with third parties, affiliate online merchants including but not limited to refunds and complaints. (c) to manage, operate, provide and/or administer your use of and/or access to our Services and the Platforms, and your user account with us suspension or termination of your user account (d) To connect you to Affiliate online merchant’s websites, application or other platforms (e) To perform audit on your account, transaction, use and access of the Services and Platform | • Moby Fintech’s relevant employees • Third Party Payment Service Provider • Affiliate online merchants • Auditor • Payment Gateway Service Provider | Identity Information, Contact Information, Purchase Information, Credit Profile, Others |
| 11. Others | ||
| (a) Other purposes to which you have consented from time to time (b) Other purposes as required or permitted by Applicable Data Protection Laws | • Moby Fintech’s relevant employees • Affiliate online merchants • Partnering businesses. | Identity Information, Contact Information, Purchase Information, Credit Profile, Others |
- (i)Cloud based storage – To store your Personal Data or files on a designated and secure private network connection through a Cloud Computing Provider in an off- site location (outside Malaysia).
- (ii)To share your Personal Data with our international affiliates, merchants and partnering service providers to enable the provision of our products and Services.
- Robust KYC processes to verify your identity;
- Secure user login and password authentication to prevent unauthorised access;
- Audit trails and logs to detect unusual activities and unauthorised access;
- Limited access to our systems and database;
- Regular security and vulnerability assessment of our Platforms;
- Regular maintenance of our Platforms to avoid bugs, error, faults in our algorithms;
- Storage of our servers, mainframes and other network assets in a secured location
- You use our Platforms and Services;
- You use platforms operated by our affiliate online merchants and partnering business to engage or find out about our products and Services; and
- You directly provide your Personal Data
- As and when required under Applicable Laws;
- Where legal actions have arisen and there are ongoing legal proceeding;