This Privacy Notice sets out how Valyou Sdn Bhd a wholly owned subsidiary of under the Merchantrade Group that is duly licensed by the Malaysian Communication and Multimedia Commission to offer telecommunication service as a, Mobile Virtual Network Operator (MVNO (“Valyou” or “we” or “us”), will collect and process personal information in accordance with the Personal Data Protection Act 2010 (“PDPA”) and the laws of Malaysia.

1. What This Privacy Notice Explains

This Privacy Notice explains:

• What kind of personal information we collect
• How we collect your personal information
• How we use your personal information
• When we disclose your personal information
• How we retain your personal information
• How we secure your personal information
• Access to and correction of your personal information
• Transfer of your personal information
• Online dealings with us

 

Please note that this Privacy Notice does not cover personal information collected or held by us about our employees and is to be read subject to any overriding provision of law or contract.

For the purposes of this Privacy Notice, please note that “Merchantrade Group” refers to Merchantrade Asia Sdn Bhd and all its related companies, as defined in Section 7 of the Companies Act 2016, and any associated companies or affiliates of Merchantrade Asia Sdn Bhd.

2. Our Commitment To You

We value the trust of our customers and business partners and are committed to protecting your personal information and ensuring that your personal information is used only for the purposes stated herein.

3. Defining Personal Information

Personal information refers to any information, which relates directly or indirectly to you and/or your transactions with us. This includes any information that can be used to distinguish, identify or contact you.

4. What Kind Of Personal Information We Collect

Because of the nature of the business carried out by us, in order for us to operate in an efficient and effective manner and provide you with the best service possible, we may collect personal information including but not limited to:

• your contact information, such as your name, address(es), telephone number(s), mobile phone number(s), fax number(s), email address(es), national identification card details, passport details, occupation details, gender, and other relevant contact information;
• IP address;
• communication information when you use our products or services e.g., traffic data, SMS, MMS and other communications, as well as the date, duration, time and cost of such communications;
• amount of data received and/or sent by you (e.g., data consumed from internet searches, uploads and downloads etc.);
• information on the equipment (e.g., mobile or fixed devices) and/or software you use when accessing our and/or Merchantrade Group’s, our preferred merchants’ and strategic partners’ products and/or services;
• your personal interests and preferences to help us tailor for you the offerings from us and the third parties to whom we disclose your personal information to;
• clickstream data when you visit any apps, social media platforms or websites;
• information relating to your transaction history with us or Merchantrade Group (e.g., transaction date and transaction ID);
• top-up or reload information (e.g., reload date, reload amount etc.);
• information relating to your use of Merchantrade Money (e.g., wallet size, Merchantrade Money Card statement), or other services offered by other members of the Merchantrade Group;
• information captured on security systems, including a recording of your image on Closed Circuit Television (CCTV) and a recording of your voice from calls made to us; and/or information you provide us regarding your marketing preferences or in the course of participating in surveys, contests or promotional offers; or
• information required to be collected in compliance with Communications and Multimedia Act 1998 and such other laws and regulations as may be applicable from time to time.

 

5. How Do We Collect Your Personal Information?

We may collect personal information directly from you when you:

• buy a product or service from us or from our authorized agents (including buying products or services online);
• apply or register for our products or services and/or by setting up an account with us;
• ask us for more information about a product or service (through verbal and/or written communication);
• from the financial transaction(s) you make, as well as from the purchase and use of reload(s) or for the services rendered by us;
• contact us with a query or complaint;
• participate in a contest, competition, or survey;
• visit or browse our website or the websites of our affiliates, authorised partners, resellers or agents; or
• engage with us via our Live chat service.

 

Other than personal information obtained from you directly (as laid out above), we may also obtain your personal information from other entities within Merchantrade Group, or third parties we deal with or connected with you, for example from communications service providers, financial institutions, credit reporting agencies, and from such other sources in respect of which you have given your consent to disclose information relating to you and/or where otherwise lawfully permitted. We also use Closed Circuit Television (CCTV) to record footage at our premises.

6. How We Use Your Personal Information

We may collect personal information from you or from the category of third parties identified above which is to be utilized for one or more of the following purposes: –

• to process your order or application for our products or services, as well as to keep you updated with the progress of your order or application;
• for identification and verification purposes, including for the purpose of conducting checks on your credit-worthiness;
• to keep you informed of our new products and services and improve our services;
• to contact you with offers or promotions based on your usage of our products or services or those of Merchantrade Group (e.g., your calling and messaging activities);
• to provide you with marketing, advertising materials and/or documents relating to products, services and/or events (including products, services and/or events of any entity in Merchantrade Group or other third party organisations with whom we may collaborate with), whether such products, services and/or events exist now or are created in the future;
• to maintain and develop our business systems and infrastructure, including conducting system testing and upgrades;
• to provide you with customer support and services;
• to respond to any queries or complaints you may have about using our products or services;
• to carry out research and statistical analysis (including but not limited to data analytics, surveys and/or profiling), and monitor customer usage of our products and services on an anonymised basis, in order to improve our or Merchantrade Group entities’ products, services and/or facilities in order to enhance any continued interaction between yourself and us or Merchantrade Group entities;
• to store your preference for certain types of information or products and/or to personalise our services to you to be retained for use in your future transactions with us;
• to prevent and detect any crime, fraud, money laundering or any other crimes; and/or

• to comply with legal and regulatory requirements, including responding to lawful requests by government or law enforcement authorities conducting an investigation.

 

CCTV footage at our branches, in particular, may also be used for the following purposes:

• for quality assurance purposes;
• to provide for the safety and security of staff, visitors and other customers;
• detecting and deterring suspicious, inappropriate or unauthorised use of our facilities;
• detecting and deterring criminal behaviour;
• to comply with legal and regulatory requirements including responding to lawful requests by government or law enforcement authorities conducting an investigation; and/or
• conducting incident investigations.

 

7. Disclosure of Your Personal Information

As a part of providing, you with our products and services and the management and/or operation of the same, we may be required or need to disclose information about you to the following third parties:

• companies and/or organisations that act as our agents, partners, service providers (including outsourced service providers) and/or professional advisers, and such parties as necessary to comply with any legal and regulatory requirements;

• any of the entities within Merchantrade Group;

• our business associates and other parties for purposes that are directly related to the purpose of collecting your personal information;
• other parties in respect of whom we are required to disclose information pursuant to a legal requirement, lawful request, or any order of court, tribunal or authority, whether governmental or quasi-governmental with jurisdiction over Valyou or Merchantrade Group or in discharge of our obligations to any regulatory authority;
• other parties in respect of whom you have given your express or implied consent; and/or
• our prospective or new owners (if any) in which instance, we would require them to adopt a policy of similar nature to protect your personal information, subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to Valyou or Merchantrade Group; or
• permitted third parties

 

8. Security of Your Personal Information

We take all reasonable precautions to ensure your personal information is protected against unauthorized or accidental loss, misuse, modification, disclosure or destruction. However, we cannot warrant or guarantee the security of personal information we transmit online, and assume no liability for alteration, interception or misuse of information transmitted via the internet.

9. Retention of Your Personal Information

It is Valyou’s policy to retain personal information for as long as it is necessary for fulfilling the purpose for which such personal information was collected, or for other purposes that is compatible with the original purpose or otherwise as required by law. Where the personal information is no longer necessary, such personal information will be permanently destroyed or deleted unless otherwise required by law.

10. Direct Marketing

We may use your personal information to provide you with information about our, Merchantrade Group, and third party services and/or products, which may be of interest or benefit to you, except where otherwise requested by you.

In certain instances, we may disclose your relevant personal information to our preferred merchants and strategic partners where your prior consent has been obtained and subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to us. We take reasonable steps to make sure that our agreements with service providers include appropriate privacy and confidentiality obligations.

If you do not wish your personal information to be utilised for the purposes of marketing or should you change your mind in relation to your previous decision, please contact us at the address detailed at the end of this Privacy Notice, we will abide by your latest written instructions to us.

11. What If Personal Information Provided By You Is Incomplete?

Where indicated (for example in registration forms), it is obligatory to provide your personal information to us to enable us to process your application for our services and/or products. Should you decline to provide such obligatory personal information, we may not be able to process your application or provide you with our services or products.

12. Your Rights To Limit the Processing of, Access And Correct Your Personal Information

Where you wish to have access to your personal information in our possession, limit the processing of personal information in our possession (e.g. to limit the processing of personal information which causes you damage or distress, or to limit the processing of personal information for direct marketing purposes), withdraw your consent to the processing of your personal information, or where you are of the opinion that such personal information held by us is inaccurate, incomplete, misleading or where relevant, not up-to-date, you may make a request to us via our Service Request Form. This form is available at Merchantrade’s branches.

We will use reasonable efforts to comply with your request to access or correct your personal information within 21 days of receiving your duly completed Service Request Form and the relevant processing fee (if any).

Please note that we may have to withhold access to your personal information in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event, we receive repeated requests for the same information. We may also have the right to refuse your request to withdraw consent to the processing of your personal data on the basis that the withdrawal of consent would impinge upon our rights and obligations as a data user under contract or law. Nevertheless, we will notify you of the reasons for not being able to accede to your request.

13. Transfer of Your Personal Information

Some or all of the information that you provide us with may, from time to time be required to be transferred outside of Malaysia. Strict rules regarding the confidentiality and safety of your information are in place to safeguard it. The transfer of your information may be made to our databases in other countries, as well as to third parties, such as telecommunications companies outside of Malaysia, to be processed. It should be noted however, that not all of these countries outside Malaysia have an “adequate level of protection” for personal information, but we will nevertheless try to take every precaution in securing the safety of any of your personal information as outlined in this Privacy Notice.

14. Information We Collect When You Visit Us Online

If you choose to obtain information or do business with us online by visiting www.hellosim.com.my you may wish to know the following:

Valyou Website

When you visit our Website, we collect standard internet log information and details of visitor behaviour patterns to ascertain the number of visitors to the various parts of the Website. Such information is not linked to you as an individual. We use such information to evaluate and improve the features, guest experience and functionality of our Website.

Cookies

We collect information about your use of our Website from cookies. Cookies are packets of information stored in your computer which assist your website navigation by customizing site information tailored to your needs. Cookies in themselves do not identify the individual user, just the computer used. You are not obliged to accept cookies. If you are concerned, you can set your computer either to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time. However, rejection of cookies may affect your use of the website as we will

be unable to personalize aspects of your use of the website.

Further information about cookies and how they work is available at www.allaboutcookies.org. To opt out of being tracked by Google Analytics across the website please visit http://tools.google.com/dlpage/gaoptout

Links To Third Party Websites

Please be informed that this Privacy Notice applies solely to our Website and does not apply to any third party websites you may access from our website. Valyou is not responsible for the privacy policies or the content of such websites as they may have privacy policies independent of Valyou. To determine how these third party websites (e.g., Twitter, Facebook, YouTube) deal with your personal information, you should ensure that you read their respective privacy policies.

15. Updates To Our Privacy Notice

We may amend this Privacy Notice from time to time. Please check our website on an ongoing basis for information on our most up-to-date practices.

16. English Version

We provide the Privacy Notice in both English and Bahasa Malaysia. In case of any inconsistencies between these two, the English version shall prevail. In case there are inconsistencies on how we collect or use your personal information between this Privacy Notice and the terms and conditions of your specific product or service or other contractual documents, the terms and conditions of your specific product or service or other contractual documents shall prevail.

17. Our Contact Details

Should you have any queries, concerns or complaints in relation to this Privacy Notice, kindly contact us during office hours (between 9.00 am to 5.00pm from Monday to Friday) at the following contact points:

Attn: Kesavan Sathasivam, Data Privacy Officer
Telephone: +603-7728-8707
E-mail: privacy@hellosim.com.my
Address: Suite 506 & 508, Level 5, Lobby 2, Block A, Damansara Intan, No. 1 Jalan SS20/27, 47400 Petaling Jaya, Selangor Darul Ehsan