TrueMoney, a subsidiary of Ascend Group, values your privacy. It is important for us to ensure that you understand how your personal data is safeguarded and the types of information received and collected by us every time you visit our website or mobile application (“Platforms”), or whenever you transact business with us.

This Privacy Policy and Statement (“Privacy Policy”) is subject to the Malaysian Personal Data Protection Act 2010 (“PDPA 2010”) as well as any other applicable laws and regulations within Malaysia.

By accessing our Platforms, interacting with us, submitting information to us, signing up for, using or continuing to use any of our products or services, you acknowledge and consent to TrueMoney, its representatives and/or agents collecting, using, processing, disclosing and sharing your personal data among themselves, as well as disclosing such personal data within Ascend Group, to TrueMoney’s authorised service providers and/or relevant third parties in the manner stated in this Privacy Policy.

Our privacy commitment

TrueMoney is committed to protecting the privacy of all personal data provided to us. TrueMoney believes that proper collection, use, processing and disclosure of personal data is important to our business and necessary for us to provide appropriate products and services to you.

Our privacy commitment applies across all of our operations, including companies within the Ascend Group and related companies and affiliates of TrueMoney.

Our privacy commitment goes beyond mere compliance with applicable privacy and data protection laws. It reflects our ongoing commitment to safeguarding the personal data entrusted to us, however collected or received, in accordance with the principles of legitimate purpose, necessity and proportionality. The following principles reflect our commitment to safeguarding personal data in our possession:

• We keep your personal data and your dealings with us in strict confidence.
• We collect, use, process and disclose personal data only for legitimate business, operational, legal and regulatory purposes, including for the provision of our products and services.
• We obtain personal data lawfully, fairly and in accordance with applicable laws.
• We do not disclose personal data except in accordance with this Privacy Policy or where otherwise permitted or required under applicable laws.
• We are responsible for personal data in our possession, including personal data transferred to third parties performing services on our behalf. Such third parties are required to protect the confidentiality and security of personal data in a manner consistent with our privacy policies, practices and applicable legal requirements.

Collection of personal data

Depending on our relationship with you, we may collect your personal data such as your name, identification number and/or passport number, gender, nationality, date of birth, photographs or other audio-visual information, telephone number(s), mailing address, email address, financial information (including bank account or credit card details), information about your interaction with our Platforms, and any other information relating to you that you may have provided to us through forms submitted to us or through other means of interaction with you.

We do not generally collect or process any sensitive personal data unless explicit consent has been obtained from you, or where such processing is otherwise permitted or required under any applicable law. However, should you voluntarily provide us with any sensitive personal data, it will be deemed that you have given us your explicit consent by conduct to collect, use, disclose or process the sensitive personal data solely for the purpose for which it was provided if it is reasonable that you would voluntarily provide the information, and in accordance with the PDPA 2010. Sensitive personal data includes, but is not limited to, the following:

• Your physical or mental health conditions;
• Your political opinions;
• Your religious belief or other beliefs of a similar nature;
• Commission or alleged commission of an offence by you; and
• Biometric data.

TrueMoney may collect your personal data through various channels and sources, including but not limited to the following:

• When you provide any information to us through any forms, applications, agreements, supporting documents, correspondence or other interactions with us;
• When you register for, access or use any of our products, services, accounts or Platforms;
• When you conduct transactions through our Platforms or otherwise interact with our products and services, including payment, remittance, reload, transfer or merchant-related transactions;
• When you communicate or correspond with us through any channel, including customer service interactions, telephone calls, emails, live chats, social media platforms or other communication channels;
• When you participate in any promotions, campaigns, surveys, contests, loyalty programmes, events or marketing initiatives organised or sponsored by us;
• When you submit identification, verification or supporting documents for onboarding, account verification, compliance, security or due diligence purposes, including any electronic know-your-customer (e-KYC) verification processes;
• When you visit, access or interact with our Platforms, including through the use of cookies, web beacons, analytics tools or other similar technologies (please refer to the section on cookies and web beacons below);
• When information relating to your transactions, device, browser, network connection, location or usage activity is automatically collected through your access to or use of our Platforms or services;
• When we receive information about you from third parties, including business partners, merchants, service providers, payment processors, verification providers, credit reporting agencies, financial institutions, regulatory authorities or other publicly available sources, where permitted by applicable laws; and/or
• When your personal data is otherwise provided to us by you or generated through your relationship or dealings with us.

For the avoidance of doubt, the above list is non-exhaustive and there may be other instances where we collect, use, disclose or otherwise process your personal data in connection with your relationship with us.

Purpose of Collection

Generally, TrueMoney collects, uses, processes, and discloses your personal data for the following purposes:

• Processing applications for our products and services, whether through manual, digital or automated processes, including account registration, onboarding, identity verification and transaction processing;
• Providing, administering and servicing our products and services to help you meet your needs, including for purposes of maintaining and improving our Platforms, enhancing user experience, improving and upgrading our systems and business processes, conducting internal administration, and appointing third-party vendors or service providers in connection with our business operations;
• Assessing your suitability for products and services, including conducting due diligence, identity verification, data analytics, market research, customer profiling and surveys aimed at improving our products, services and customer experience;
• Informing you of TrueMoney’s products and services, including sending marketing, promotional, rewards, campaign or advertising materials relating to our products and services through phone calls, mail, email, SMS, push notifications or other electronic communication channels, subject always to applicable laws;
• Complying with applicable laws, regulations, directives, guidelines, circulars, orders, issuance by, or agreements and obligations of TrueMoney to any competent authority, regulator, supervisory body, enforcement agency, exchange, court, quasi-judicial body or tribunal, including obligations relating to anti-money laundering, counter-terrorism financing, fraud prevention, sanctions screening and regulatory reporting;
• Identifying, investigating, preventing and detecting financial crimes, suspicious transactions, unauthorised activities, fraud, bribery, money laundering and terrorist financing, including but not limited to the submission of reports, disclosures or notifications to the relevant Anti-Money Laundering competent authorities or enforcement agencies;
• Enforcing and/or defending the rights, interests and legal position of TrueMoney before any agency, court, tribunal, quasi-judicial body, regulator or authority, including for the purposes of legal proceedings, dispute resolution, investigations, audits and enforcement actions;
• Recognising and carrying out other lawful or legitimate commercial, operational or business purposes necessary for the performance of, or in relation to, a contract, transaction or service to which the data subject is a party;
• When necessary or desirable in the context of an employer-employee relationship between TrueMoney and the data subject, including for human resource administration, internal management and employment-related purposes; and/or
• Enabling TrueMoney to exercise governance over its businesses and ensuring that risks arising therefrom are duly identified, measured, monitored, managed and mitigated, including for internal audit, compliance, operational, security and risk management purposes.

Where you provide personal data relating to another individual to TrueMoney (including your directors, officers, employees, representatives, authorised persons, customers or other related individuals), you represent and warrant that you have obtained the necessary consent, authority and/or lawful basis to disclose such personal data to TrueMoney and for TrueMoney to collect, use, process and disclose such personal data in accordance with this Privacy Policy and applicable laws. You further represent and warrant that the relevant individuals have been notified of the matters set out in this Privacy Policy, including the purposes for which their personal data may be processed and disclosed.

Disclosure and transfer of your personal data

While bearing in mind your privacy rights, the public interest in the availability of the data, and as necessary for the provision of our products and services to you, we may disclose, share or transfer your personal data (whether within or outside Malaysia) to the following third parties:

• Any companies within the Ascend Group, its directors, officers, employees, duly authorized representatives, related companies and affiliates;
• Third party service providers and vendors including credit card processors, data analytics and customer support providers, and IT service providers and marketing tool providers who are bound by an obligation of confidentiality. They will have access to your personal data only as necessary to perform their requested function on your behalf, and if they have adequate security and privacy standards acceptable to TrueMoney;
• Any authority, regulator, supervisory, enforcement agency, exchange, court, quasi-judicial body or tribunal;
• Professional advisers including accounting, tax, financial or legal counsel;
• Banks, financial institutions, payment networks, business partners, merchants or other parties involved in facilitating transactions or services requested by you;
• Regulatory authorities, government agencies or statutory bodies pursuant to any laws or regulations; and/or
• Any person, entity or third party to whom you authorise, instruct or consent to the disclosure of your personal data.

By continuing to engage with us, use our products or services, or access our Platforms, you acknowledge and consent to the disclosure, sharing and transfer of your personal data to such third parties (whether within or outside Malaysia) where such disclosure, sharing or transfer is necessary for the purposes set out in this Privacy Policy or otherwise permitted under applicable laws.

TrueMoney takes reasonable and appropriate security measures to ensure that any disclosure of your personal data to any third parties is implemented in a safe and secure manner. These measures include (i) controlled access and role-based permissions; (ii) encryption of data prior to transmission; (iii) secured channels or platforms for data sharing; and (iv) maintaining logs or audit trails for all disclosures made.

Security of your personal data

As we value your personal data, we will ensure an adequate level of protection. We have therefore implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.

Online security of your personal data

Unless you choose to identify yourself, you may browse certain parts of our website anonymously. However, where personal data is required, you may be prompted by our systems to provide the necessary information. Similarly, if you create an account with us and wish to access such account online, you may be required to provide information acting as an identifier for authentication and security purposes. TrueMoney has implemented safeguards to protect your personal data against unauthorised use, improper access, disclosure, alteration or destruction. Such safeguards may include the following:

• Passwords and personal identification numbers (PINs): Your passwords and PINs are unique to you, and are an important first step in protecting your information online.
• 128-bit encryption: TrueMoney uses a Secure Sockets Layer (SSL) protocol to protect personal data transmitted to us electronically. SSL transmitted information is encrypted, or scrambled, to prevent unauthorised reading of the electronic communication.

While TrueMoney takes reasonable steps to safeguard your personal data through physical, electronic and procedural security measures, you acknowledge and understand that no method of transmission over the internet or electronic storage system is completely secure. Accordingly, TrueMoney cannot guarantee that personal data provided online will not be accessed, intercepted, modified, disclosed, deleted or otherwise misused by unauthorised parties, including as a result of human error, operational failures or circumstances beyond our reasonable control.

Protecting your personal data

The processing of your personal data exposes you to financial, legal, regulatory or reputational risks that may result from the unauthorised processing or disclosure of personal data. TrueMoney is committed to protecting the privacy of all personal data provided to us. We maintain physical, technical and organizational safeguards to protect your personal data against loss, theft, unauthorised access, disclosure, copying, use or modification.

We limit access to those who have a business need to know. We are responsible for all personal data in our possession, including information transferred to third parties performing services on our behalf. All such persons, wherever they are located, are required by us to protect the confidentiality and privacy of your personal data in a manner consistent with our privacy policies and practices.

Online data collection tools: improving and evaluating website functionality and effectiveness

TrueMoney, like many organisations, may collect certain information, such as your IP address, to better understand how visitors use and navigate our Platforms. We may collect information relating to the number of new and repeat visitors, the pages visited, the duration of visits, approximate geographic location, device or browser information and other similar usage data.

We may also track how users interact with advertisements or promotional materials relating to our products and services that may appear on third-party websites or platforms. Such information is generally collected in an aggregated or non-identifiable form and is used to improve the performance, functionality and security of our Platforms, enhance user experience, evaluate the effectiveness of web marketing campaigns and provide you with more relevant content, products and services based on your possible interests.

TrueMoney, or third parties acting on our behalf, may collect such information through the use of cookies, analytics tools and electronic images known as web beacons.

Cookies and web beacons

A cookie is a small piece of information that a website or mobile application sends to your device, where it is stored on your browser or device storage. In our effort to make your next visit to our Platforms more convenient, TrueMoney may use the information stored in your cookies. A cookie does not identify you personally unless you have chosen to provide your identity to us. Cookies also cannot access other information or files from your device. There are 2 types of cookies – session cookies and permanent or persistent cookies.

A session cookie (sometimes called a “transient” cookie) is erased when you close your Internet browser and leave our website or mobile application. In some countries, only session cookies are used.

A “permanent” cookie is a file that remains on your device when you close your Internet browser or mobile application. A permanent cookie can be read only by the website or mobile application that created the cookie when you revisit that site or application. Permanent cookies may not be used in all jurisdictions in which TrueMoney operates.

Cookies may identify a visitor only if the visitor has used a website or mobile application login feature. If you request for your login credentials or account information to be saved for future visits, we may use a permanent cookie to store such information in an encrypted format on your device so that you may be recognised when you sign in again. In this way, the website or mobile application may recall your preferences and provide a more customised experience.

Permanent cookies have expiry dates and are automatically deleted from your device after their expiry date. You may also clear your stored cookies through your browser or device settings. However, unless you have configured your settings to disallow cookies, a new cookie may be added the next time you visit our Platforms. You may configure your browser or device settings to notify you when you receive a cookie so that you may decide whether to accept or reject it. Since the procedure for altering such settings varies depending on the browser or device used, you should refer to the relevant “Help” or support section for further information. Please note, however, that rejecting cookies while visiting a TrueMoney website or mobile application may result in certain parts of the Platforms not functioning properly or as efficiently as intended.

Certain cookies placed by third-party advertising, analytics or service providers may be used to improve the relevance of advertisements or content that you may see on other websites, mobile applications or online platforms. You may manage or opt out of certain cookies through your browser, device or applicable third-party provider settings.

Web beacons are a collective term used to refer to “pixel tags”, “web beacons” or “clear GIF images” embedded in a web page or mobile application and are usually invisible to the user.

Web beacons are used for many of the same purposes as cookies, allowing TrueMoney or third parties acting on behalf of TrueMoney to compile aggregated statistics relating to usage patterns on our Platforms, such as how many times a link or particular area of a website or mobile application is clicked. Information collected through these online tracking tools is generally collected in an aggregated, statistical or non-directly identifiable form and is not ordinarily used together with information that directly identifies you personally unless such information is linked with your account or other identifying information.

We may share information collected through cookies, web beacons and similar technologies with analytics providers or other third-party service providers for purposes of analysing online activities on our Platforms, improving functionality and user experience, or evaluating the effectiveness of our online advertisements and marketing campaigns.

Online privacy

TrueMoney has implemented physical, electronic and procedural safeguards to help protect personal data provided through online transactions, activities and interactions conducted through our Platforms.

We may also use online data collection tools and similar technologies to improve functionality, enhance security, evaluate the effectiveness of our Platforms and advertising campaigns, and provide users with a more customised online experience. For further information regarding our use of cookies, web beacons and similar technologies, please refer to the relevant sections of this Privacy Policy.

Links to websites outside of TrueMoney

To provide visitors with additional information or services that may be useful to them, our Platforms may contain links to third-party websites, mobile applications or online platforms that are not affiliated with, operated or maintained by TrueMoney.

TrueMoney does not monitor, control or have authority over the privacy practices, content, security or data collection practices of such third-party sites or platforms. Accordingly, you acknowledge and understand that TrueMoney shall not be responsible or liable for the privacy policies, data collection practices, content or procedures of such third-party websites, mobile applications or platforms.

You are encouraged to review the applicable privacy policies and terms of use of such third-party websites, mobile applications or platforms before providing any personal data or using such services.

Interaction between you and TrueMoney

We are interested in your views, and we value feedback from our clients and visitors. We, therefore, have set up notice boards, newsgroups, feedback, email, forum facilities and/ or chat rooms. If at any time our Platforms offer any chat rooms, notice board facilities, newsgroups etc., we may collect the personal data that you disclose.

Such information will be used in accordance with this Privacy Policy. However, we cannot control or be responsible for other parties’ use of the personal data which you make available to them through our Platforms. We encourage you to be careful about what personal data you disclose in this way.

Comments

TrueMoney’s Platforms may include interactive sections, such as comment sections, forums, feedback channels or similar features where users may post or share content. Please note that any information disclosed through such areas may become publicly accessible and you should exercise caution when deciding to disclose your personal data or other sensitive information. You acknowledge and understand that TrueMoney shall not be responsible or liable for any information or personal data that you choose to publish or disclose through such public or interactive sections of our Platforms.

Special notice – if you are a minor (under the age of 18) under Malaysian law

Our Platforms are not directed at or intended for individuals under the age of 18 or such other age regarded as a minor under applicable laws, and we do not knowingly, deliberately or intentionally collect, use, disclose or otherwise process the personal data of individuals under the age of 18. However, if any individual under the age of 18 provides us with personal data, it shall be deemed and represented that the necessary consent has been obtained from such individual’s parent, legal guardian or person having parental responsibility for the collection, use, disclosure and processing of such personal data in accordance with this Privacy Policy.

Keeping our records accurate

We aim to keep our information about you as accurate as possible. If you would like to review, change or delete the details you have supplied us with, please contact us as set out below.

How long we will retain your personal data

Your personal data will be retained by TrueMoney for as long as necessary for the purposes that it has been collected for. Thereafter, we may continue to retain your personal data for a further period of up to 7 years (“Retention Period”) in order to satisfy any legal or regulatory requirements, to protect our legitimate interests, or for any other lawful purposes. After the Retention Period, we will anonymize, destroy or permanently delete the personal data that is no longer required.

Your rights as data subjects

As data subjects, we recognise that you may have certain rights under the PDPA 2010, including the right to request access to and correction of the personal data that we hold about you. You may also withdraw your consent to the processing of your personal data as set out in this Privacy Policy, including withdrawal of consent for direct marketing purposes, by contacting us through the contact details provided below.

Please note that the withdrawal of your consent may affect our ability to continue providing certain products, services or functionalities to you.

Before processing any request relating to your personal data, we may require sufficient information from you to verify your identity and validate the request for security and verification purposes. Where permitted under applicable laws, TrueMoney reserves the right to refuse or impose conditions on such requests.

Updates and changes

TrueMoney reserves the right, at any time, to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Platforms and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Platforms. By continuing to interact with us, submitting information to us or using any of our products or services, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time.

Contact information

If you have any questions, concerns, complaints or wish to exercise your rights in relation to your personal data, please contact our Data Protection Officer at dpo_truemoney@hhq.com.my.

Language

This Privacy Policy is available in both English and Bahasa Malaysia. In the event of any inconsistency between the English version and the Bahasa Malaysia version of this Privacy Policy, the English version shall prevail.

Effective Date: 1st August 2026

Last Review Date: 1st August 2026