Karuna (Sarawak) Enterprise Sdn. Bhd. (Company No. 972491-T), a private limited company incorporated under the Companies Act, 1965 and having its registered address at No.67, 3rd Floor, Jalan Tun Jugah, 93350 Kuching, Sarawak, Malaysia (hereinafter referred to as “KARUNA”) respects the privacy of individuals and understands that privacy is a concern of its users; we shall, therefore, take reasonable steps to safeguard any personal data gathered by S PAY PROPERTIES. Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATION.

This Personal Data and Privacy Policy have been formulated in accordance with the Personal Data Protection Act 2010 (“Act”). For the purpose of this Personal Data and Privacy Policy, “Personal Data” shall have the meaning ascribed to it in the Act.

This Personal Data and Privacy Policy inform you of KARUNA’s policy and practices in regards to data privacy matters which you may be concerned with, before you provide your personal data to KARUNA via its services known as S PAY PROPERTIES.

KARUNA may change this Personal Data and Privacy Policy from time to time and we will notify you, by email, or by means of notice on S PAY GLOBAL websites. You are also advised to check the said policy on a regular basis.

A. PURPOSE OF COLLECTION OF PERSONAL DATA

  1. By providing any of your Personal Data: your name, gender, age, date of birth, nationality, identity card number, contact details, occupation, preferences, interests and/or other information relevant to the purposes listed below to KARUNA via the internet or otherwise, you hereby agreed that KARUNA shall collect, retain and use the Personal Data for the following purposes:
    • To set up, activate and manage your S PAY PROPERTIES account;
    • To consider your request for a product or service;
    • To assist in arrangements with other organizations (such as billing companies), both within or outside Malaysia, in relation to the provision of a product or service;
    • Fulfil and manage purchases, orders, payments, refunds and other transactions related to S PAY PROPERTIES.
    • Processing your application under any KARUNA programme;
    • Promotion of new products, services, mobile applications, interactive features and/or recommendations;
    • Notifying you of special offers or new services, updates and promotions;
    • Carrying out of matching procedures in accordance with the law;
    • Increase the efficiency and operations of S PAY PROPERTIES;
    • Contact regarding your account or order;
    • Request feedback and contact you about your use of S PAY PROPERTIES;
    • Resolve disputes and troubleshoot problems;
    • Enable user-to-user communications;
    • Generate a personal profile about you to make future visits to S PAY PROPERTIES more personalized;
    • Monitor and analyse usage and trends to improve your experience with S PAY PROPERTIES;
    • Monitor and perform statistical analyses of your behaviours and characteristics in order to measure interest in and use of the various services of the site and providing this information to merchants, billers together with information as to the number of users that have been exposed to or clicked on their banners;
    • Compile anonymously statistical data and analysis for use internally or with third parties;
    • Prevent fraudulent transactions, monitor against theft, and protect against criminal activity;
    • Making such disclosures as may be required for any of the above purposes or by law.
  2. You further agree that KARUNA may disclose and transfer (whether in Malaysia or abroad) to KARUNA’s agents, contractors, partners, advertisers, network operators, associated companies, any relevant financial institutions, or any other persons under a duty of confidentiality to KARUNA, any company within its group, any referee whose details are provided by you and any of KARUNA’s actual or proposed assignees or transferees of KARUNA’s rights with respect to you to use, disclose, hold, process, retain or transfer such Personal Data for the purposes of A1 herein, for and on behalf of KARUNA. We may also use your Personal Data to send you promotional information about other third parties which we think you may find interesting. If you do not want to receive such information or for us to disclose, transfer or use your Personal Data for any of the purposes described in A1, you may contact us in writing at the address set out in E2 below.
  3. Please note that in the event that sufficient Personal Data is not supplied, or is not satisfactory to KARUNA, your application or request to KARUNA for any of the above purposes of A1 may not be accepted.
  4. Any Personal Data supplied by you will be retained by KARUNA for as long as necessary for the fulfilment of the purposes stated in A1 herein or is required to satisfy legal regulatory or accounting requirements or to protect KARUNA’s interests.

B. CONFIDENTIALITY

  1. This Personal Data and Privacy Policy is pursuant to any applicable law that may from time to time be in force.
  2. Any questions, comments, suggestions or information, other than Personal Data, sent or posted to the site, or any part of the site, by visitors will be deemed voluntarily provided to KARUNA on a non-confidential and non-proprietary basis. KARUNA reserves the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely, including passing it to any associated company, for example, in connection with the development, manufacture and marketing of products and services and to meet customer needs.

C. SAFETY OF PERSONAL DATA

  1. All reasonable efforts and practical steps are made to ensure that any Personal Data held by KARUNA is kept up-to-date and is protected against any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. While we have taken reasonable steps to secure the personal information that you have provided to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

D. LINKS

  1. S PAY PROPERTIES may contain links to other sites and pages. By activating a link, for example, by clicking on the banner of an advertiser, you leave our website. KARUNA does not exercise control over any Personal Data or any other information you give to any other entity after you have left our website. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from S PAY PROPERTIES.

E. 3rd Party Push Notification SDK

  1. In order to provide you with push notification services, S PAY PROPERTIES integrates with Google Firebase, which will collect your device information.
  2. Device information includes: device identifier (IMEI, IDFA, Android ID, MAC, and unique identifier of device compilation), application information (application crash information and notification switch status), and device parameters & system information (device type, device model, operating system and hardware related information like device system version, mobile phone system version).
  3. You may refer to Google Firebase Privacy Policy for more info: https://firebase.google.com/support/privacy

F. RIGHT OF ACCESS TO PERSONAL DATA

  1. Under the Act, you have the right of access to your Personal Data held by KARUNA and to request the correction of any Personal Data that is inaccurate, incomplete, misleading or not up-to-date.
  2. If you have any questions regarding KARUNA’s Personal Data and Privacy Policy or if you wish to request access to your Personal Data or if you wish to correct your Personal Data or if you wish to withdraw your consent to KARUNA for the processing of your Personal Data for the purposes of A1 or for the transfer of your Personal Data to the third parties stated in A2, you may send your request in writing to the following address:

    Karuna (Sarawak) Enterprise Sdn. Bhd.,
    No. 67, 3rd Floor,
    Jalan Tun Jugah,
    93350, Kuching,
    Sarawak, Malaysia.
    Attention: Property Axis

    or via email :

    Email: [email protected]

    with the Subject: PDPP – S PAY PROPERTIES

    Please note that in the event you withdraw your consent to KARUNA for the processing of your Personal Data for the purposes of A1, KARUNA shall cease to process your Personal Data upon receipt of aforesaid withdrawal request wherein your approved application or request to KARUNA for any of the above purposes of A1 may be cancelled.

G. HOW LONG DOES KARUNA KEEP YOUR PERSONAL DATA?

  1. KARUNA will keep your personal data for the duration of the time necessary to carry out the purpose for which your personal data was collected and also for the other purposes set out in this Personal Data and Privacy Policy.
  2. KARUNA reserves the right to access, read, preserve, and disclose any information it reasonably believes is necessary to:-
    • Satisfy any applicable law, regulation, legal process or governmental request;
    • Enforce the Terms of Service or other user policies and agreements, including investigation of potential violations thereof; detect, prevent, or otherwise address fraud, security or technical issues