Debit Circles Sdn Bhd (hereinafter, “Vircle”, “we”, “us”, or “our”) (Company Registration No. 1307991-X) respects privacy and we are committed to protecting all Personal Information (as outlined here) collected and kept by us, in accordance with the relevant laws (including the Personal Data Protection Act, 2010), this Privacy Notice and our Terms of Use. Keeping customer information secure and using it only as our customers would want us to, is a top priority for all of us at Vircle.

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For the avoidance of doubt, unless the context requires otherwise, the words used in this Privacy Notice shall have the same meanings stipulated in the Terms of Use as outlined within our application or at our website http://www.vircle.com

By using our Services, you agree to the terms of this Privacy Notice and you will be deemed to have consented to the collection, use and disclosure of your Personal Information in accordance with this Privacy Notice.

 

The Vircle Privacy Policy

1. Ensures that we safeguard through the best of our ability, technology, laws of the country, according to strict standards of security and confidentiality, any information our customers share with us.

2. Ensures that we will limit the collection and use of customer information to the minimum as may be required to deliver  the best customer experience and service to our customers, which includes advising our customers about our products, services and other opportunities, and to administer our business.

3. Ensures that only authorized personnel and employees of Vircle, who are trained in the proper handling of customer information, to have access to information which are deemed personal and private.

4. Ensures that when we collaborate with any 3rd parties which require sharing of personal data from Vircle, we will require them to conform to our privacy standards.

 In this Privacy Policy, we explain the following:

• Personal Information we collect and how we collect it;

• How we use your Personal Information;

• The parties that we disclose the Personal Information to; and

• The choices we offer, including how to access and update your Personal Information.

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Collection of Personal Information

The information we collect is information that we require in order to perform our services and offer our products to you. This information is categorized into 2 types,

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• Account registration information – information such as your name, email address and other relevant information required for proper functioning of the application.
   

• Regulatory information – Vircle uses E-wallet financial technology provided for by its Partner, Fass payment Sdn Bhd (”Fasspay”), regulated under the Malaysian Financial Services Act (FSA) 2013. As part of this partnership and regulation, we are mandated by Fasspay to adhere to strict “Know Your Customer” identity collection and verification. These are information we are mandated to collect, such as Identity card or passport details and photograph, are verified and from time to time reported back to the regulators such as Bank Negara Malaysia (BNM) but not limited to; as requested on the legitimate identity of users using this service. 

 

• 3rd Party Identification information - Vircle is all about giving to your loved ones, called “Vircle Friends”. Before you give approvals to your Vircle friends, you will need to add them to your Vircle Friends list. In doing so, we will collect additional “Know Your Customer” Identification information on your Vircle Friend. This shall include legal identity information and additional information such as Food allergies and notes to store owners on your Vircle friend.

 

• Usage information - From time to time, we may also collect information that pertains to you directly through the usage of the Vircle application or indirectly through other sources (if any). When we do so, we require the third party to confirm that the information was legally acquired by them and that we have the right to obtain it from them and use it. The information that we collect, either directly or indirectly, may be combined to help us improve its overall accuracy and completeness and to help us better tailor our interactions with you.

If you are below the age of eighteen (18), you are responsible to obtain consent from your parent, guardian or person who has parental responsibility, prior to disclosing your personal details to Vircle.  We shall not be liable for any loss or inconvenience to you for failing to obtain consent.

 

Use of Personal Information

The personal information you give us shall be used in several instances, as described below (but not limited to);

 

Fulfilling your “V Give” Transaction Request

When you V Give an approval to your Vircle friends, or when any of your Vircle Friends consume from your Vircle e-wallet, we constitute that as a transaction service within the Vircle Platform. We will use the information you provide to fulfil your request. To help us do this, we may share information with others, for instance, Vircle E-Wallet Partner, Fasspay or financial institution partners. In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.

Personalizing your Experience across our Services

We may use information we collect about you to provide you with a personalized experience on our Vircle application and websites, such as providing you with content in which you may be interested and making navigation on our sites easier.

Marketing

• The information you provide to Vircle, as well as the information we have collected about you indirectly, may be used by Vircle or its approved partners for marketing purposes directly from the relevant company(s).
  The information that we may disclose for the purposes of marketing may include but not limited to the following:

  • Personal information such as date of birth, age and Vircle friend details

  • Consumption details such as how much is spent by yourself or your Vircle friends within the Vircle ecosystem or service.

• Customers’ transaction details for marketing analysis purposes.
  You may at any time inform us if you do not wish to receive marketing communications from us or our related corporations by contacting us directly (please refer to “Questions and Concern” below). Your latest written instructions to us shall prevail.

Protect the Rights and Property of Vircle

We may also use or share your information to protect the rights or property of Vircle, our business partners, suppliers, clients, or others when we have reasonable grounds to believe that such rights or property have been or could be affected. In addition, we reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights, or the rights of others, or to comply with a judicial proceeding, court order, or legal process served on our websites.

 

Collection and Use of Non-Personal Information

We also collect non-personal information/data in a form that does not permit direct association with any specific individual. We may collect, use, transfer and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

1. We may collect information such as occupation, language, postcode, area code, unique device identifier, location and the time zone where our Vircle  products or services are used, so that we can better understand customer behavior and improve our products, services and advertising.

2. We also may collect information regarding customer activities on our websites and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our websites, products and services are of most interest. Aggregated data is considered non-personal information for the purposes of this Privacy Statement.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

 

Disclosure of Information

Vircle complies with the data protection laws in Malaysia and takes all reasonable care to prevent any unauthorized access to your personal data. Vircle and those working for agents or contractors of  Vircle have the responsibility to keep your information confidential and will only use it to offer products and services on behalf of Vircle.

At times, as a part of providing you with our products and services and the management and/or operation of the same, Vircle may be required or need to disclose your information with certain classes of third parties. However, Vircle will not disclose any document or information relating to your affairs and accounts with us unless such disclosure is permitted under the Financial Services Act 2013. Data shared will be for the purpose as stated in this privacy statement, or purposes not stated but directly related to the primary purpose of collection.

The classes of third parties that Vircle may divulge the personal information of its customers are as follows:

1. Persons/Organizations required under law or where disclosure is necessary for the purposes of compliance with applicable laws or in response to relevant authorities’ requests;

2. Government agencies, statutory authorities, enforcement agencies under law;

3. Vircle  auditors, accountants and solicitors;

4. Vircle business partners or service/product providers that are deemed necessary or appropriate for the purposes stated above including for the purposes of fraud investigation;

For the avoidance of doubt, Vircle shares its customers’ personal information with companies who provide services such as information processing, extending credit, fulfilling customers’ orders, delivering products to customers, managing and enhancing customers’ data, providing customer service, assessing customers’ interest in Vircle’s products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Vircle operates (including those located out of Malaysia, under conditions of confidentiality and similar levels of security);

1. Persons under a duty of confidentiality to Vircle;

2. Government authorities or relevant parties for the purpose of investigation on any matters relating to products offered by Vircle; an

3. Any class of third parties expressly stated in this Privacy Statement. 

 

Information Security and Accuracy

Vircle takes precautions including administrative, technical and physical measures to safeguard your personal information against loss, theft and misuse, as well as against unauthorised access, disclosure, alteration and destruction. Furthermore, we intend to protect your personal information and to maintain its accuracy. Vircle implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure.

 

Integrity and Retention of Personal Information

Vircle makes it easy for you to keep your personal information accurate, complete and up to date. We will retain your personal information for as long as your account is active or as needed to provide you services.

 

Access and Correction to Personal Information

Under Personal Data Protection Act 2010 (PDPA), you reserve the right to access your personal data and request for correction of the personal data that might be inaccurate, obsolete, incomplete or misleading.

 

To access your personal data, you can:

1. Request to check and access your personal data in our records;

2. Request that we correct any of your inaccurate, obsolete, incomplete or misleading personal data; and

3. Request copies of the data from us.

Once we receive a request, we will acknowledge the receipt of such request. For data amendment and correction, we will consider if the information requires amendment. If there is any disagreement, then we specify the reason in clearly stated terms such as where rights of others will be violated, or regulatory functions will be affected.

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Vircle reserves the right to decline to process requests:

1. Where Vircle is not supplied with sufficient information as to the identity of the requestor or of the relevant person making the request;

2. Where Vircle is not supplied with sufficient information to enable it to locate the personal data;

3. Where the burden or expense of providing access is not proportionate to the risk of the data subject’s privacy;

4. Where Vircle cannot comply with the request without disclosing the personal data of another individual who is identifiable from that information. However, this can be provided if Vircle is satisfied that the other individual has consented to the disclosure of the information to the requestor or it is reasonable in all circumstances to comply without the consent of such other individual;

5. The processing of personal data is controlled by another data user in a manner which prohibits the relevant data user from complying in whole or part with the request;

6. Where it will be against any court order;

7. Where it will disclose confidential commercial information; or

8. Where the access is regulated by another law.

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Access, correction, deletion requests or any enquiries and complaints can be made online via the Vircle Website Support Chat or in app within the Vircle application “Contact Us” function. We shall endeavour to correct such information change request within 21 days.

If you wish to request that we no longer use your personal data or limit the usage of your personal data in anyway whatsoever, you may contact us at support@vircle.com

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However, please note that Vircle may not be able to proceed with the provision of the relevant product or services and you may not be able to use such product and services thereafter.

The personal data requested by Vircle are mandatory for the relevant product or services which you must provide and agree to the processing of such personal data. Should you decide not to provide any or all of the personal data, Vircle may not be able to proceed with the provision of the relevant product or services and you may not be able to use such product and services thereafter.

 

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Use of Cookies

Our websites create a “cookie” when you first register online. A “cookie” is a piece of information, like a tag, which some basic information which helps us to identify if you have visited the site before and if you have provide us with some personalized content such as welcoming you by name if you have supplied this in a previous visit. However, as it is based on your PC, we will not find the “cookie” if you visit our website from a different PC to the one you registered on. The use of “cookies” includes the following assurances:

No information regarding your telephone number, an account or payment details included in the cookie or can be accessed using it; and

They do not collect any personal information regarding the use of your PC or internet browsing in any way.

If you do not want a “cookie” to be created on your PC, web browsers such as Internet Explorer, Mozilla Firefox of Google Chrome provide the option to disable them. Please bear in mind that some personalized services on our websites may not be available if you choose to disable cookies.

Vircle also uses third parties to track its advertising across the web. The information these third parties collect does not include any personal information but is merely for the purpose of identifying the general effectiveness of such online advertising.

 

Our Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to all our employees and strictly enforce privacy safeguards within the company.

 

Changes to this Privacy Statement

The Vircle team may review and update its Privacy Statement from time to time to reflect changes in the law, our business practices, procedures and structure, and the community’s changing privacy expectations. When any such updates and/or revisions are made, it should be notified to you via email . 

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Questions or Concerns

If you have any question or concern, you may reach us at support@vircle.com