XenoPay is owned and operated by Ionnex Sdn Bhd ("XenoPay", "Us", "We", or "Our"). This Privacy Policy describes how we collect, use, disclose, process and protect personally identifiable information ("Personal Data") that you (the "User") may provide in connection with XenoPay services available through the Apps ("Platform") at XenoPay App ("Site"). Personal data means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access. By visiting or using the Apps, you agree and consent to the collection, use, disclosure and processing of your Personal Data in accordance with this Privacy Policy and/or the App Terms. If you do not agree to the Privacy Policy below, please leave the Apps immediately.

From time to time, XenoPay may revise this Privacy Policy to reflect changes in the law, our Personal Data collection and use practices, the features of our Apps, or advances technology. If we make revisions that change the way we collect or use your Personal Data, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy. Therefore, you should review this Privacy Policy periodically so that you are up to date on our most current policies and practices. XenoPay will also prominently post such material changes prior to implementing the change. If you do not agree with any changes or modifications to the Privacy Policy, please do not continue use the Apps. You will be deemed to have consented to any modification of the Privacy Policy when you use the Apps after the effective date of the modification.

1. Information We Collect

   We collect Personal Data about you that you provide to us when using the Apps. Such Personal Data includes but is not limited to your name, IC, XenoPay user identification and login credentials, address, mobile number, email address, activity in the Apps ("Redemption, and/or Purchased"). We may request you to provide information on your transaction through your XenoPay purchased. We also collect non-personally identifiable information (that cannot be used to identify you), including but not limited to your internet protocol ("IP) address, geographic location data, operating system type, nationality, search preferences, as well as other generic Internet usage related data.

2. How We Use Your Information

   We may use your Personal Data and other information gathered through the Apps, whether in Malaysia or overseas, for the following purposes:

   • Registering, managing, and/or administering your use and/or access of the Apps;
   • Managing, operating, administering and providing you the services offered on the Apps;
   • For contacting you on matters relating to your use and/or access of the Apps and services on the Apps, and any enquiries and/or request submitted by you through the Apps;
   • To customize your experiences when using the Apps;
   • Measuring and improving customer experience and stratification;
   • Publishing customer reviews, such as of the Apps, Merchants, Voucher, or Products, in digital and/or print format for public access;
   • To enforce our Terms and Conditions;
   • To resolve disputes or complaints, collect payment or fees, or troubleshoot problems;
   • And/or for the purpose otherwise notified to you at the point of collection

   We may also use your Personal Data and other information collected for Social Media marketing using direct and open graph techniques and for digital and conventional marketing purpose such as sending you direct mailers and post about new products, special offers or other information which we think you may find interesting. Please not note that you may opt out if any marketing materials we may send to you at any time. Please follow the unsubscribe instructions set out in our marketing materials if you choose to opt out any marketing materials and we will respect your wishes.

3. Sharing and Transferring Your Personal Data

   Your Personal Data will/may be disclosed to by XenoPay to XenoPay affiliates companies. XenoPay (and/or its affiliates companies) may also disclose your Personal Data to third party service provider, merchants, supplies or agents for one or more of the above purposes from time to time. Third party services include but are not limited to data analysis, marketing, processing credit card transactions, and services provision.

   In some cases, when you transact directly with a third party to obtain services, or when you use the Apps to purchase a point or obtain another product or services, we may provide your Personal Data to that Merchant or third party.

   Depending on your locations, XenoPay, its affiliate companies and its third party service providers, merchant or agents may also be transferring your Personal Data overseas.

   Please note that XenoPay may disclose your Personal Data in following situations:

   • To bring or defend against any claims or suits;
   • To comply with court orders, judicial processes, legitimate requests warrants or equivalent by law enforcement officials or the authorities;
   • To investigate fraud or other wrongdoing or as otherwise required or necessary in order. To comply with any applicable law, or to protect our legitimate interests;
   • To the purchases in connection with any sale, assignment, or other transfer all or part of our business or company;
   • To enforce or apply the terms and conditions applicable to our products and services;
   • To protect the rights, property or safety of XenoPay, other Apps Users, or any other person according to XenoPay's discretion; and
   • For any other situations, which is allowed under law.
4. Consent

   As stated above, by browsing and using the Apps, or by do transaction (purchasing) a product from the Apps, or by registering for or using the services on the App, or by clicking the "Confirm" button or equivalent when you create a new account on the Apps, you:

   • Consent to XenoPay and/or XenoPay's affiliate companies collecting, using, disclosing and/or processing your above mentioned Personal Data for the purpose as described above; and
   • Consent to XenoPay and/or XenoPay's affiliate companies transferring your Personal Data out of Malaysia to other XenoPay affiliate companies where such other XenoPay affiliates companies are sited, and to XenoPay's (or XenoPay affiliate companies) third party service providers, merchant or agents for the purpose as described above.
5. Withdrawing Consent

   You may withdraw your consent to our collection, use or disclosure of your personal data at any time, by giving us reasonable notice. If you wish to withdraw your consent, please inform us at our contact details listed below. We will cease to collect, use or disclose your personal data upon notification, unless required by law or if we have legitimate business or legal purposes for retaining it. Note that by withdrawing your consent to our collection, use or disclosure of your personal data, we may not be able to continue providing you with our services and you agree that we will not be liable to you for any losses or damages arising out of or in relation to such termination of services.

6. Access to or Correction of Your Personal Data

   When you provide us with your Personal Data, please ensure that it is accurate and complete. If you believe that any of your information under our possession or control contains errors or omissions, please log into your account on the Apps and correct the information. In addition, please update your Personal Data through your account in a timely manner, should there be any changes.

   If you wish to correct an error or omission in any Personal Data under our possession or control that cannot be corrected via our Apps, or to access your Personal Data under our possession or control, or as provided for by applicable laws, please submit your request to our contact details listed below. We may charge you a reasonable fee for access to the Personal Data, for the purpose of recovering the incremental costs of responding to the access request.

   To protect your privacy and security, we will verify your identity before granting access or making changes to your Personal Data. We will endeavour to answer requests for access or correction to your Personal Data as soon as reasonably possible, unless an exception applies.

7. Protecting Your Personal Data

   We protect Personal Data under our possession or control by maintaining reasonable security arrangements, including physical, technical and organizational procedures, to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

8. Link to Other Websites

   Our Apps may contain links to other websites/apps of interest. However, once you have used these links to leave our Apps, you should note that we do not have any control over that other website/Apps. Please note that we are not responsible for the privacy practices of such other websites and advise you to read the privacy statements of each website you visit which collects personal information.

9. Registration and Memberships

   This Apps allows you to create a user account with the membership register, based on the data you provide. By providing the data, registering, and creating your account, you warrant that:

   • You are at least 18 years of age;
   • Information about you is true and accurate, current and complete as required in the registration form on the Apps (the "Registration Data"); and
   • You will update this Registration Data to keep it true, accurate and complete.

   Further, you agree that XenoPay is not responsible for any loss or damages that may be suffered by us, you or any third parties, where such loss or damage is caused by inaccurate or incomplete information given by you. After registering, you will receive a password and user identification ("Username"). You are responsible for maintaining the confidentiality of the password and Username, and you are fully responsible for all activities related to the Username or password. You can only use a single Username and password at one time and are not allowed to use more than one Username. Your password is strictly for your own personal use only, and you agree to keep your password strictly confidential. You agree to immediately notify XenoPay about unauthorized use of your password or account or any other breach of security. For greater security, please ensure that you logout or exit from your account after each use of this Site. You agree that XenoPay will not be liable for any loss or damage suffered by us, you or third parties arising from your failure to comply with this clause.

10. Transfer of Business

    In the event of a change of control or change of ownership of all or part of the XenoPay business or company, including the Apps, then all Users' Personal Data may/will be part of the transfer of such assets.

11. Approval of Privacy Policy Changes

    By using the Apps or the services we provide, you agree to the collection, use, disclosure and processing of your Personal Data as set forth in this Privacy Policy. Furthermore, if you use our services, we reserve the right to collect, use, disclose and process your Personal Data in accordance to this Privacy Policy. From time to time, XenoPay may change this Privacy Policy. As described in the beginning of this Privacy Policy, we will display the changes on this Apps for your information.

12. Order of Precedence

    If you have agreed to our Apps Terms, in the event of inconsistency between such Apps Terms and this Privacy Policy, such Apps Terms shall prevail.

13. Disclaimer

    Note that as we are a Malaysia registered company, this Privacy Policy has been drafted solely in accordance with the laws of Malaysia. We do not represent or warrant that this Privacy Policy complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Privacy Policy as such.

    For the avoidance of doubt, for the exceptions where the law permits an organisation such as XenoPay to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.

14. Contact Us

    If you have any questions or requests relating to this Privacy Policy, please contact our Data Protection Officer at the following details, or such person as XenoPay may designate by informing you through any letter, invoice, email.