Privacy Policy

HappieToken understands that our users care about their personal data and how it is collected, used, shared, and cared for. We are committed to handling your personal data in accordance with the applicable laws when you use any of the features, functions, mini-apps, or mobile games available on our Platform or Services, interact with us via an external service, application or through our customer service agents, or access our Services or our Platform through your computer, mobile device, or any other device with Internet connectivity.

1. 1. Introduction to this Privacy Policy
2. 2. The Personal Data We Collect From You
3. 3. Use and Disclosure of Your Personal Data
4. 4. Withdrawal of Consent to Continued Use, Disclosure, Storing, and/or Processing of Personal Data
5. 5. Updating Your Personal Data
6. 6. Accessing and Correcting Your Personal Data
7. 7. Security of Your Personal Data
8. 8. Retention of Personal Data
9. 9. Minors
10. 10. Third-Party Sites
11. 11. Questions, Feedback, Concerns, Suggestions, or Complaints
12. 12. Privacy Policy for Corporate Company Users

1. Introduction to this Privacy Policy

1. HappieToken and its affiliates (collectively or individually, "HappieToken", "we" or "us") take your privacy seriously. Depending on your location, the HappieToken entity controlling your personal data will be HT Voucher Trading Sdn Bhd.
2. This Privacy Policy should be read in conjunction with any future country-specific provisions that may apply as our business activities expand into additional jurisdictions.
3. In the course of you using HappieToken’s applications and websites (both web and mobile versions), as well as products, information, functions, and other services operated by HappieToken, we will be collecting, using, disclosing, storing, and/or processing data, including your personal data. In this Privacy Policy, Platform shall refer to all relevant applications and websites (both web and mobile versions), and Services shall refer to all products, information, functions, and services provided by HappieToken from time to time at the Platform(s).
4. This Privacy Policy exists to keep you in the know about how we collect, use, disclose, store, and/or process the data we collect and receive during the course of providing the Services or access to the Platform to you, our user, whether or not you have registered to use our Platform as a buyer or a seller. We will only collect, use, disclose, store, and/or process your personal data in accordance with this Privacy Policy.
5. It is important that you read this Privacy Policy together with any other applicable notices we may provide for special applications where we are collecting, using, disclosing, and/or processing personal data about you, so that you are fully aware of how and why we are using your personal data.
6. We may update this Privacy Policy from time to time. Any changes we make to this Privacy Policy in the future will be reflected on this page and material changes will be notified to you. Where permissible under local laws, your continued use of the Services or access to the Platform, including placing Orders (as defined in the Terms of Use) on the Platform, or express consent thereto, following the modifications, updates or amendments to this Privacy Policy (whether or not you have reviewed such document) shall constitute your acknowledgment and acceptance of the changes we make to this Privacy Policy. You agree that it is your responsibility to review and check the Privacy Policy frequently to see if any updates or changes have been made to this Privacy Policy.
7. This Privacy Policy applies in conjunction with other notices, contractual clauses, and consent clauses that apply in relation to the collection, storage, use, disclosure, and/or processing of your personal data by us and is not intended to override them unless we state expressly otherwise.
8. All of these terms apply to HappieToken's users, whether or not the users have created an account as buyers and/or sellers, unless otherwise stated specifically to apply only to buyers or only to sellers.

2. The Personal Data We Collect From You

1. We collect the personal data described below in accordance with applicable local laws and, if required, upon obtaining your consent.
2. Personal data means any information about an individual, whether recorded in a material form or not and whether true or not, who can be identified from that data (whether directly or indirectly), or from that data and other data to which we have or are likely to have access.
3. Depending on your use of our Platform and/or your interaction with our Services (such as when registering for our Services and/or logging into our Platform), you may be asked to provide us with certain information. While you can choose not to provide us with certain information, you might not be able to take advantage of many of our Services that are provided to you. The personal data that you may opt to provide to us includes:
   1. Identity and Profile Data, which may include your name, date of birth, gender, username and password, email address, telephone number, your interests, and any personal data in any photographs or videos or audio recordings that you upload onto our Platform.
      1. Where you are a seller, we may also collect your company name, address, date of incorporation, and other business-related information (e.g., company registration number, business license, tax information, shareholder, and director information).
   2. Account and Transaction Data, which may include your credit card details, bank account details, bank statements, delivery/billing address, payments and orders to and from you, and other details of products and services that you have supplied to or purchased through the Platform.
   3. Usage Data, such as information about how and when you use the Platform, products, and Services or view any content on the Platform, as well as websites you were visiting before you came to the Platform and other similar statistics.
   4. Marketing and Communications Data, which may include your interests, survey responses, preferences in receiving marketing materials from us and your communication preferences, your preferences for particular products or services, as well as your feedback, chat, email, or call history on the Platform or with third-party service providers.
   5. Location data, such as when you check for deals near you or the delivery/pick-up status of orders.
4. We automatically collect and process certain types of information when you use your devices to access our Platform and interact with our Services for the purposes set out herein.

How We Receive Your Personal Data

5. During the course of your use of the Platform and our provision of the Services, we may receive personal data from you in the following situations:
   1. When you browse our websites (both mobile and web versions);
   2. When you create an account with us (as buyer, seller, or otherwise);
   3. When, as a seller, you list products and/or services for sale on the Platform and/or on the platforms of our affiliates and conduct transactions with buyers in respect of the sale and purchase of those products and/or services;
   4. When you apply for, subscribe to, or otherwise use any of the Services on our Platform and/or on the platforms of our affiliates;
   5. When you make a transaction regarding the products available on the Platform;
   6. When you activate or use any payment-related functions available on the Platform or provided by our third-party service providers;
   7. When you use any of the features, functions, mini-apps, or mobile games available on the Platform or Services;
   8. When you record any user-generated content which is uploaded on the Platform;
   9. When you use the chat function on the Platform;
   10. When you subscribe to our publications or marketing collaterals;
   11. When you enter a competition, promotion, or survey;
   12. When you participate in any activity or campaign on the Platform;
   13. When you log in to your account on the Platform or otherwise interact with us via an external service or application, such as Facebook or Google;
   14. When any other user of the Platform posts any comments on the content you have uploaded on the Platform or when you post any comments on other users’ content uploaded to the Platform;
   15. When a third party lodges a complaint against you or the content you have posted on the Platform; and
   16. When you interact with us offline, including when you interact with our outsourced customer service agents.
6. We may collect personal data from you, third parties (including but not limited to agents, vendors, contractors, partners, and any others who provide services to us, who collect your personal information and/or perform functions on our behalf, or with whom we collaborate, including but not limited to payment service providers, government sources of data, financial services providers, credit bureaus, delivery, marketing, and other service partners), our affiliates, or such data may be collected automatically when you use the Platform or the Services, as set out in this section. Please see also Sections 2.12 to 2.16 on the collection of computer data.
7. During the course of your use of the Platform and our provision of the Services, you agree that you have provided your consent (whether to us, the third party, or our affiliates) to the transfer of your personal data from third parties and/or our affiliates to HappieToken for the purposes set out in this Privacy Policy or any other terms.
8. You agree to only submit personal data that is accurate and not misleading and to keep it up to date and inform us of any changes to the personal data that you have provided to us. We shall have the right to request documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required under law.
9. We will only be able to collect certain categories of personal data if you voluntarily provide the personal data to us or as otherwise provided for under this Privacy Policy. If you choose not to provide your personal data to us or subsequently withdraw your consent to our use of your personal data, we may not be able to provide you with certain features or functionality on the Services or access to the Platform.
10. In some situations, you may provide personal data of other individuals to us (such as your family members or friends or persons in your contact list), when you use the "Find My Friends" or similar function, or when you add them as recipients or beneficiaries of any use of our Services. You represent and warrant that you have obtained the necessary consent, license, and permissions from such individuals to share and transfer their personal data to us, and for us to collect, store, use, disclose or otherwise process that data in accordance with this Privacy Policy.
11. If you sign up to be a user on our Platform using your social media account or link your HappieToken account to your social media account or use certain other HappieToken social media features, we may access personal data about you which you have voluntarily provided to your social media provider in accordance with the provider's policies, and we will manage your personal data in accordance with this Privacy Policy.

Collection of Computer Data

12. We or our authorized service providers may use cookies, web beacons, and other similar technologies in connection with your use of the Services or access to the Platform.
13. When you visit the Platform through your computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website, such as the technical data and usage data outlined in Section 2.2 above.
14. This data is collected for analysis and evaluation to help us improve our website and the services and products we provide, as well as to help us personalize the content to match your preferred interests more quickly. The data is also collected to make the Services and the Platform more convenient and useful to you and to provide more relevant advertising related to market products, services, and features to you.
15. Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognize a particular device or browser. Web beacons are small graphic images that may be included on our Services and the Platform. They allow us to count users who have viewed these pages so that we can better understand your preferences and interests.
16. You may be able to manage and delete cookies through your browser or device settings. However, certain cookies are required to enable core functionality (such as adding items to your shopping basket), so please note that changing and deleting cookies may affect the functionality available on the Platform or through our Services.

3. Use and Disclosure of Your Personal Data

Purpose of Use

General Purpose

Your personal data is used for various purposes, following local laws and, if necessary, after obtaining your consent.

Specific Purposes Based on Your Relationship

Depending on whether you're a buyer, seller, or just visiting the platform, your personal data may be used for the following:

1. Platform and Service Facilitation
   1. Assisting with your platform use or services.
   2. Managing your online account with us.
2. Analytics and Research
   1. Improving user experience and tailoring platform content.
   2. Identifying platform visitors.
   3. Conducting surveys and demographic research, improving technologies (e.g., machine learning).
   4. Performing data analysis to enhance our services.
3. Legal and Operational Reasons
   1. Fraud detection and identity verification.
   2. Handling complaints and regulatory requirements.
   3. Compliance with legal or governmental requests.
   4. Ensuring the safety of users and employees.
4. Any Other Agreed Purpose
   1. Using your data for purposes agreed upon when consent is given, ensuring adherence to applicable laws.

Additional Uses Based on Buyer or Seller Status

For Buyers

When you place an order or use services:

1. Order Processing: Processing and delivering your orders, including sharing data with third-party logistics providers.
2. Payment Verification: Ensuring smooth transaction processes.
3. Service Provision: Responding to inquiries and displaying profile information.
4. Marketing: Sending promotions and relevant content.
5. Other: Gaining insights on customers and using automated decision-making tools.

For Sellers

When you sell products on the platform:

1. Order Fulfillment: Shipping products and handling delivery issues.
2. Transaction Verification: Managing payment processes.
3. Service Provision: Assisting in onboarding and dispute resolution.
4. Marketing: Promoting seller services through campaigns.
5. Other: Gaining insights into sellers and supporting automated processes.

Disclosure of Personal Data to Third Parties

Sharing with Third Parties

We may share your data with third parties like:

1. Service Providers: For payments, logistics, marketing, etc.
2. Affiliates: Related companies or service providers.
3. Legal Authorities: Governmental bodies or regulatory authorities.
4. Other Platform Users: For specific platform features (e.g., user-generated content).

Security and Retention

We ensure that third parties protect your personal data and only retain it for as long as needed.

International Data Transfers

Cross-border Transfers

We may transfer your personal data across jurisdictions, adhering to legal requirements and informing you about the countries involved.

Third party services

Third Party Providers

Your personal data may be shared with third-party service providers (e.g., for payments). These providers are governed by their own privacy policies, and any issues with their services should be directed to them.

4. Withdrawal of Consent to Continued Use, Disclosure, Storing, and/or Processing of Personal Data

1. Withdrawal Process

   You may withdraw your consent regarding our continued use, disclosure, storage, and/or processing of your personal data at any time. To do so, please contact us using the information provided below. This withdrawal is subject to any conditions or limitations set by applicable laws or regulations.

2. Impact of Withdrawal

   Please note that if you choose to withdraw your consent to our use, disclosure, storage, or processing of your personal data for the purposes outlined above, or if you exercise any other rights available to you under local laws, we may no longer be able to provide you with certain Services or fulfill any ongoing contracts we have with you. In such cases, we will not be held liable for any inability to continue providing these Services or fulfilling the contract. Our legal rights and remedies remain fully reserved should this situation arise.

3. Opting Out of Marketing Communications

   You may choose to stop receiving marketing information from us at any time by updating your preferences in your profile settings within the application or by using the unsubscribe feature included in the electronic marketing materials we send.

5. Updating Your Personal Data

1. Accuracy and Responsibility

   It is essential that the personal data you provide to us is accurate and complete to ensure uninterrupted use of the Platform and proper delivery of our Services. You are responsible for notifying us of any changes to your personal data, especially if you believe that the information we have is inaccurate, incomplete, misleading, or outdated.

2. Self-Service Updates

   You can update your personal data at any time by accessing your account settings on the Platform.

3. Sharing Updates

   We may share updates to your personal data with third parties and affiliates who have previously received your information, provided it is still necessary for the purposes described in this Privacy Policy.

6. Accessing and Correcting Your Personal Data

1. Requests for Information or Corrections

   You have the right to request information about the personal data we have collected from you, including details on how your personal data has been used, disclosed, stored, or processed. You may do this through your personal account settings on our Platform or by contacting us using the details provided inSection 11 below. Additionally, you may request corrections to any inaccuracies or omissions in your personal data. To assist in processing your request, we may need additional information. Where permissible by law, we reserve the right to deny correction requests that are deemed frivolous or unreasonable.

2. Administrative Fees

   Where allowed by applicable data protection laws, we may charge a reasonable administrative fee for retrieving your personal data records. If such a fee applies, we will inform you in advance before processing your request.

7. Security of Your Personal Data

1. Protective Measures

   To protect your personal data from unauthorized access, collection, use, disclosure, processing, modification, disposal, or misuse, we have implemented appropriate administrative, physical, and technical security measures, such as:

   1. Restricting access to personal data to authorized personnel;
   2. Utilizing secure technologies to prevent unauthorized computer access;
   3. Employing 128-bit SSL (Secure Sockets Layer) encryption technology when processing financial information; and
   4. Implementing additional security measures as required by applicable laws.

2. Internet Security Risks

   While we take security seriously and strive to protect your information, please note that no method of data transmission over the internet or electronic storage is completely secure. As such, we cannot guarantee absolute security. We are committed to continually reviewing and enhancing our security protocols. You are also advised to exercise caution when sharing personal or security information (e.g., passwords, credit card details) outside of our Platform or Services.

8. Retention of Personal Data

1. Retention Period

   We will retain your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required or permitted by law.

2. Secure Disposal

   When it is reasonable to conclude that your personal data is no longer necessary for the purposes it was collected for, and there is no legal or business reason for further retention, we will securely dispose of or anonymize the data, ensuring it is no longer associated with you.

9. Minors

1. Restriction on Minors

   We do not sell products or provide Services to minors, as defined by applicable law, nor do we knowingly collect personal data from minors. Our Platform and Services are not intended for use by individuals below the age of majority.

2. Confirmation of Age

   By using our Platform, you confirm and warrant that you are above the age of majority and fully capable of understanding and accepting the terms of this Privacy Policy. If you are a minor, you may only use our Platform with the involvement of a parent or legal guardian.

3. Responsibilities of Parents or Guardians

   Parents and legal guardians should ensure that minors under their care do not submit personal data to us. If personal data belonging to a minor is disclosed to us, you, as the parent or legal guardian, consent to the processing of the minor’s personal data under the terms of this Privacy Policy, and you agree to take full responsibility for their actions.

4. Responsibility for Unauthorized Use

   We are not liable for any unauthorized use of our Services on the Platform by you, individuals acting on your behalf, or unauthorized users. It is your responsibility to make informed decisions regarding the use of our Services and to take appropriate measures to prevent any misuse of the Platform.

10. Third-Party Sites

1. Links to External Websites

   Our Platform may include links to websites operated by third parties, such as business affiliates, merchants, or payment gateways. We are not responsible for the privacy practices of these third-party websites. You are encouraged to review the applicable privacy policies of those websites to understand how they handle any personal data they collect.

2. Independent Privacy Policies and Practices

   Even if a third party is affiliated with us, we have no control over their websites, which may have separate privacy and data collection practices. We disclaim any responsibility or liability for the content, security measures (or lack thereof), or activities of these linked sites. These links are provided for your convenience, and you access them at your own risk. Nevertheless, we aim to maintain the integrity of our Platform and its links, and we welcome feedback regarding these linked sites, including instances where a link may not be functioning.

11. Questions, Feedback, Concerns, Suggestions, or Complaints

1. Frequently Asked Questions

   If you have questions regarding personal data protection or privacy matters, please refer to our frequently asked questions section dedicated to data protection and privacy issues.

2. Contact for Further Inquiries

   For any concerns regarding our data protection or privacy practices, or if you wish to exercise your rights under applicable laws, please contact us via email.

This Privacy Notice is available in both English and Bahasa Malaysia. In case of any discrepancies between the two versions, the English version shall prevail.

12. Privacy Policy for Corporate Company Users

1. Applicability to Corporate Entities

   In addition to the privacy rights and obligations outlined in Sections 1 to 11, this section applies specifically to corporate users who utilize the Platform to shop for digital cash vouchers on behalf of their company or organization. Corporate users acknowledge and agree that their company’s data, including any personal data of employees or agents shared during transactions on the Platform, is subject to this Privacy Policy.

2. Collection of Corporate Data

   When a corporate entity uses the Platform to purchase digital cash vouchers, we may collect and process corporate-specific information, such as:

   1. Company name, registration details, and tax information
   2. Corporate representative details, including name, job title, and contact information
   3. Transaction data related to the purchase of digital cash vouchers This data will be treated with the same level of protection and care as individual personal data as described in Sections 5 to 8 of this Privacy Policy.

3. Consent from Corporate Representatives

   Corporate users must ensure that their representatives (e.g., employees or agents) provide the necessary consents for the collection, use, and processing of their personal data in accordance with this Privacy Policy. The corporate user is responsible for informing such individuals about the contents of this Privacy Policy and securing their consent where required by law.

4. Use of Corporate Data

   We use corporate data to facilitate the purchase and management of digital cash vouchers, provide customer support, and ensure compliance with legal obligations (such as tax reporting). Corporate data may also be used for purposes related to internal analytics, performance monitoring, and improvements to our Services, as described in Section 3.

5. Sharing of Corporate Data

   Corporate data may be shared with our affiliates, partners, or third-party service providers where necessary to complete transactions, process payments, or fulfill legal obligations, as outlined in Section 3.7. We take measures to ensure that such data sharing is done securely and in compliance with applicable laws.

6. Access, Correction, and Retention of Corporate Data

   Corporate users may request access to or correction of the corporate data collected by us, as provided in Section 6. Corporate data will be retained in accordance with the principles outlined inSection 8. We will retain such data only for as long as necessary to fulfill legal or business purposes.

7. Security Measures for Corporate Data

   We employ industry-standard security measures to protect corporate data from unauthorized access or disclosure, as described in Section 7. Corporate users are advised to implement internal security protocols to safeguard any access credentials or sensitive data when using our Platform.

8. Liability for Unauthorized Use

   Corporate users are responsible for ensuring that only authorized representatives have access to the Platform and for preventing unauthorized use of corporate accounts. We disclaim liability for any unauthorized transactions made by individuals acting on behalf of the corporate user, as outlined in Section 9.

9. Compliance with Corporate Policies

   Corporate users are expected to comply with their internal corporate policies regarding data privacy and protection when using the Platform. We are not responsible for ensuring such compliance but will cooperate with corporate users to address any concerns or inquiries regarding data privacy, as provided in Section 11.