PRIVACY POLICY

Last updated on 25 September 2018.

 

Presto Pay Sdn Bhd (formerly known as EPP Solution Sdn Bhd) (Company No.: 795818-U) (“PPSB”) recognises that information about our customer is an integral element to the operations and nature of our business. We consider the protection and confidentiality of your personal data to be important and are committed to safeguarding and protecting your personal data in accordance with the provisions of the Personal Data Protection Act 2010 (“PDPA”).

 

PPSB operates the mobile application(s) with the name of “Presto” (“Presto App”). This Privacy Policy has been established to provide a better understanding of our policies and procedures regarding the collection, storage, use and disclosure of information for our services on Presto App.

 

By utilising Presto App (including content, features, links, services and tools), you represent that you have read, understood, accepted and agreed to be bound by all the terms and conditions stipulated in this Privacy Policy. If you do not agree with any terms and conditions in this Privacy Policy, we strongly advise against the utilisation of Presto App.

 

The terms “we”, “us”, “our” or “PPSB” shall refer to Presto Pay Sdn Bhd.

 

The terms “you” or “your” shall refer to all persons utilising Presto App.

 

(​​​​​a) You can browse Presto App without telling us who you are or revealing any personal information about yourself. Once you sign up or log in to your account and give us your personal information, you are not anonymous to us.

 

(b) You should note that Presto App may collect the following types of personal information in order to enable your utilisation of the features and functionality of Presto App (and for any other additional purposes that may be set out in this policy):

  1. (i)   name and contact details such as phone number and/or mobile number, e-mail address, physical address and in certain circumstances financial information related to method of payment;
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  3. (ii)   corporate details in the event that you are acting in the capacity of a legal entity;
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  5. (iii)   transactional information based on the pattern of your browsing or purchasing or sales activities on Presto App, billing and other information that is necessary in order to complete the purchase or delivery of item, material, service or content;
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  7. (iv)   personal information that is furnished to Presto App through correspondence, chats, dispute resolution, or shared by you from other social applications, services or websites;
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  9. (v)   further personal information that Presto App may require you to submit for the purposes of authenticating and identifying yourself in the event that we believe you may be in violation and/or in breach of site policies (e.g. Presto App may request for you to send an identification or to answer additional questions online to supplement the verification of your identity). This policy is necessarily in place for security purposes and to protect your personal data;
  10.  
  11. (vi)   other information from your interaction with Presto App, services, content and advertising, including computer and connection information, statistics on page views, traffic to and from Presto App, ad data, IP address etc.;
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  13. (vii)   information from other companies, such as demographic and navigation data;
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  15. (viii)   aggregate information such as non-identifying, general, and generic information which may be collected through the utilisation of Presto App to better design the website and to improve the features and functionality of the Presto App.
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(c)   Provision of personal information through Presto App shall be voluntary unless where it is indicated as mandatory. Where personal information is indicated as mandatory, failure to provide such information may result in PPSB not being able to process your request completely.

 

(d) Your personal information may be collected for the purposes of determining your eligibility for participating in different reward based promotional activities, competitions, surveys, lucky draws and provision rewards and prizes as may be prescribed from time to time by PPSB (“Campaign”). Such personal information may include but is not limited to, your name, address, e-mail address, phone number, social media/network identification, etc. Any Campaign as may be launched or organised through the Presto App shall be solely undertaken by PPSB only (unless explicitly expressed otherwise with the mutual agreement of other parties) which shall be effective for period of time as may be determined by PPSB at its absolute discretion.

(a)   Our primary purpose in collecting and using the personal information is to provide you with a safe, smooth, efficient and customized experience on Presto App.

 

(b)   We shall endeavour to use the information collected to:

  1. (i)   provide the services requested by you;
  2.  
  3. (ii)   provide customer support, resolve dispute and troubleshoot problems or for such other communication purposes to facilitate our services;
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  5. (iii)   prevent potentially prohibited or illegal activities and enforce our terms of use;
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  7. (iv)   customize, measure and improve our services, content and advertising;
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  9. (v)   send you targeted marketing, service updates, and promotional offers;
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  11. (vi)   improve the features and functionality and content of Presto App, and keep you notified with regards to updates to Presto App; and
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  13. (vii)   compare information for accuracy, and verify it with third parties.

 

(c)   Your personal information that is collected in accordance with Section 1(d) shall be publicly manifested and/or exhibited on an electronic notice board or by other means of notification that PPSB may deem reasonable and accessible as a performance indicator in relation to your participation in PPSB’s promotional activities, competitions, surveys or lucky draws for the duration of the Campaign only or such other period of time as may be determined by PPSB.

(a)   The main channel of communication for Presto App is via e-mail or notification within the Presto App or such other mode as may be determined by PPSB. Upon registration of an account, a welcome e-mail or notification will be sent to you for verification purposes. Transactional e-mails or notifications for operations such as account management, billing or system maintenance shall also be communicated via e-mail or notification within the Presto App.

 

(b)   Presto may from time to time communicate to you related information such as announcements, updates, promotions, newsletters, surveys or other marketing and commercial notices or particulars and/or updates incidental to any Campaign via e-mail or notification within the Presto App or on www.prestouniverse.com.

 

(c)   At any time, you may choose to opt out of receiving these communications from Presto App by updating your preferences under your account settings in Presto App or by e-mailing to us at support@prestouniverse.com to remove your contact details from our e-mail list.

(a)   The acceptance of this Privacy Policy means that we may use your personal information for marketing purposes and to communicate to you the features and functionality offered by Presto App. This essentially allows Presto App to deliver targeted marketing and promotional offers based on your communication preferences but this can be unsubscribed at any time through clicking the unsubscribe link.

 

(b)   We do not sell, rent or share your personal information with non-affiliated companies and/or people for direct and/or indirect marketing purposes without your express consent.

 

(c)   We may use and share your non-personal information for marketing purposes including, without limitation, marketing on other websites, e.g. using of information to control the number of times you have viewed an advertisement and to deliver advertisements based on your interests and to measure the effectiveness of such campaigns.

 

(d)    If you would like to stop such tailoring of advertisements on other websites, you may prevent or stop us by deleting the cookies (which is further illustrated in Section 6) of your browser.

(a)    We do not sell, trade or rent your personal information with others.

 

(b)   We may share your personal information with third party service providers who help with our business operations or perform functions on our behalf under contract with us.  They have restricted access to personal information needed to provide their service or perform their functions, but may not use it for any other purpose.

 

(c)   We may share your personal information with third parties to whom you expressly request or consent us to disclose such information when listing an offering for sale or making a purchase or utilising a specific service as may be offered by the Presto App.

 

(d)   We may share your non-identifying information with third parties for the purpose of communicating promotional offers. We may from time to time send offers to selected groups of users on behalf of other businesses. If you do not want to receive such offers, you may unsubscribe through the Presto App or by sending an e-mail to support@prestouniverse.com.

 

(e)    Your personal information may be shared in response to legal compliance and/or requirements with law enforcement officers or governmental officials where there may be a verified request relating to a criminal investigation or alleged illegal activity, or protection of one’s safety, property or rights. In such event, we may disclose information such as name, address, contact number, account details (including username), IP address, fraud complaints, listing and/or transaction history, etc. in accordance with applicable laws and regulations.

 

(f)   If we have reasonable grounds to believe that you are in breach of any of the terms and conditions of this Privacy Policy, or if requested by the relevant governmental authorities, private investigators, all rightful owner(s) or interest holder(s) and/or injured third parties or as a result of a subpoena or other legal action, we reserve the right, in our sole and absolute discretion to give full cooperation to the relevant governmental authorities, private investigators, all rightful owner(s) or interest holder(s) and/or injured third parties in the investigation of any potential or ongoing criminal or civil wrongdoing. We shall not be liable for damages or results arising directly or indirectly from the disclosure in accordance with the foregoing and you agree not to bring an action against PPSB for such disclosure and/or actions.

 

(g)   In the event that we plan to merge with or be acquired by another business entity, your personal information may be transferred in conjunction with that combination transaction. The sale or transfer of PPSB and/or all or part of its assets may result in your personal information being sold or transferred in the process. Should such information transfer occur, we will require that the transferee acts in accordance with this Privacy Policy with respect to your personal information.

 

(h)   Where a foreign recipient is receiving your personal information, we shall undertake all reasonable steps to ensure that such disclosure is in accordance with applicable laws and regulations and is not in breach of privacy obligations.

 

(i)   We shall to the best of our reasonable endeavours ensure that any personally identifiable or transactional information with any person and/or entity is not shared other than in circumstances as set out in this Privacy Policy.

 

(j)   We enable you to share personal information for the purposes of completing transactions. When you are involved in a transaction, you may have access to other user's personal information which includes but not limited to, the full name, user ID, e-mail address, contact details and postage information. In view of the foregoing, you must comply with data protection laws, and provide other users an opportunity to withdraw their personal information from your database and also the option to review the personal information you have collected.

 

(k)   Pursuant to paragraph (j) above, you agree to only use other user’s information in the following manner that is:

  1. (i)    for the fulfillment of the transaction through Presto App and purposes related thereto;
  2.  
  3. (ii)    the utlisation of services as may be offered through Presto App; or
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  5. (iii)    for other purposes as may be expressly indicated by the user.

 

(l)   We may use third parties to supply and/or deliver rewards and prizes which would necessitate the sharing of your personal information for fulfillment purposes. These third parties are prohibited from using your personal information for any other purposes and we endeavour to take all reasonable steps to ensure that your personal information is handled in a manner that is consistent with the PDPA and/or any other legislation related to the protection of personal information.

(a)   We use "cookies" (small files placed on your hard drive) on certain of our pages to help analyse our web page flow, customise our services, content and advertising, measure promotional effectiveness, and promote trust and safety. 

 

(b)   A few important things you should know about cookies are:

  1. (i)    we offer certain features that are available only through the use of cookies;
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  3. (ii)   we use cookies to help identify you and maintain your signed-in status;
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  5. (iii)   most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session;
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  7. (iv)   you are always free to decline our cookies if your browser permits, although doing so may affect your experience when utilising the features and functionality of Presto App; and
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  9. (v)   you may encounter cookies from third parties on certain pages that we do not control. (For example, if you view a web page created by another user, there may be a cookie placed by that web page.)

(a)   Your password is the key to your account. Use unique numbers and letters and do not disclose your password to anyone. If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify us and request for change of your password. 

 

(b)   We will not ask for your password by phone or e-mail. If you receive such enquiry, please report the incident to us at support@prestouniverse.com.

Your information is stored on our servers located in Malaysia. We treat data as an asset that must be protected using tools (encryption, passwords, physical security, etc.) to protect your personal information against unauthorised access and disclosure. However, as you probably know, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your personal information that they collect from Presto App. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private. 

(a)   Presto App may contain links that direct you to other websites or external content and resources which are not within our control. Those links are provided for your convenience and information.

 

(b)   Whilst we will use our best endeavours to ensure that those links direct you only to websites which share our privacy and security standards, we would like to assert that we are not in the position to guarantee the same. Therefore, we will not be held responsible for the protection and privacy of any personal data which you provide on any external non-affiliated websites.

 

(c)   Those other websites may have their own privacy statement in place and we strongly recommend that you exercise caution by reviewing the privacy policy of those websites before disclosing any information.

(a)   You may at any time access or update your personal information through the account profile settings online. If you believe that any personal information that we hold or have recorded about you is inaccurate, incorrect, or incomplete, you may request an amendment or clarification of it. We recommend that you keep your information as current as possible so that we may continue to improve our services to you.

 

(b)   You are entitled to access any personal information that we hold about you at any time by contacting us at support@prestouniverse.com. Upon request of such access, we will endeavour to provide you with an adequate means of accessing it (e.g. by e-mailing it to you or providing notification within the Presto App). We will not incur a charge for simply satisfying the request or making any corrections to your personal information.

 

(c)   There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality or law. In that event, we will provide you written reasons for any refusal.

We reserve the right, at any time in our sole and absolute discretion to revise our privacy policy with or without notice which will be effective upon posting. Any updated versions of this Privacy Policy will be posted on Presto App and we encourage that you review this page regularly for any changes or updates. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of any amendments.