Privacy notice

We at Tranglo respect and protect privacy of personal data we receive or collect. This Privacy Notice sets out the type of personal data we process and how we use such personal data.

If you are from Malaysia, this Privacy Notice is also available in Bahasa Malaysia here.

All defined terms used in this Privacy Notice are set out in the Glossary below.

Who Are We

Depending on where you are located or which Tranglo Entity you are dealing with, the following Tranglo Entity shall be responsible for the processing of Personal Data:

Collection of Personal Data

1. How we collect your Personal Data
   1. You give us Personal Data when you:
      1. open an account for the purpose our services;
      2. enter into an agreement with us;
      3. fill in any form on our Site;
      4. correspond with us to enquire or lodge a complaint relating to our services; or
      5. furnish us with more information when required by us.
   2. Information from others
      We may collect your Personal Data from third parties such as the Individual Customer, Business Customer, financial services provider and identity/verification services provider.
   3. Information collected automatically
      For details, see our Cookie Policy
2. Types of Personal Data collected
   We collect:
   1. name, date of birth and governmental identification number;
   2. contact details such as address, email address and phone number;
   3. details of your bank account or e-wallet;
   4. details of your debit card and credit cards;
   5. photograph image of you and your identification document;
   6. information of your device including the technical information relating to it;
   7. information on transaction such as date, time, amount, currency, exchange rate and payout method;
   8. record of our correspondence or discussions, orally or in writing.

Processing Personal Data

1. How we use your Personal Data
   Generally, we will process the Personal Data collected for the following purpose:
   1. to fulfil our legal and regulatory requirements in jurisdictions where we operate;
   2. if you are a Business Customer, a Representative or Individual Customer, to conduct know-you-customer verification for onboarding purpose;
   3. If you are a Business Customer, a Representative, Individual Customer, Sender or Beneficiary, to conduct the necessary identity verification and screening; and to process any instructions; and
   4. if you are a Visitor to our Site, for more details how we will process your Personal Data, see our Cookie Policy.
2. Sharing of Personal Data
   We may share the Personal Data with the following ways:
   1. Tranglo’s Affiliate. We share Personal Data with other Tranglo’s affiliates for the purposes set out in this Privacy Notice.
   2. Our Service Provider. To provide our Business Customer and Individual Customer our services, we may rely on third party service providers, which includes any financial institution, payment service provider, e-wallet operator, e-money operator, money remittance service provider, or any licensed institution in a serial or cover payment chain that receives and transmits a transaction for and on behalf of another entity. In doing so, we may disclose Personal Data to these service providers but only to the extent necessary and permitted by laws. We will also require these service providers to protect the security and confidentiality of the Personal Data they process on our behalf.
   3. Compliance. Where we reasonably believe that it is necessary to share Personal Data in order to comply with:
      1. any laws and regulations;
      2. any rules imposed by any organisation relating to the use of specific payment method;
      3. any contractual obligations including enforcing our contractual rights; and
      4. with any order or request by courts, regulatory authority, law enforcement agencies and any public or government authorities.
   4. Corporate Transactions. If we or our affiliate enter into any transaction that will alter the structure of our business or shareholdings such as merger, reorganisation, assignment, joint venture or sale, we may share certain Personal Data with third parties necessary for such transaction. We will ensure that any recipient of Personal Data protect the security and confidentiality of these Personal Data.
   5. Any person whom you have consented. Where required, we may reach out to you to seek your consent to share the Personal Data to a third party and when we do so, we will inform you the identity of these third party and the type of Personal Data we intend to share with them.
3. Legal Basis for Processing of Personal Data
   1. Your consent. You are able to remove your consent at any time by contacting us at [email protected]. Notwithstanding that, we may still retain some critical Personal Data to comply with our legal obligation.
   2. Contractual obligation or Pre-contractual relationship. We process Personal Data for the purpose of entering into relationship with potential Business Customer and Individual Customer and to perform contractual obligations we have with these Business Customer and Individual Customer.
   3. Compliance of Legal Obligations. We process Personal Data to verify the identity of any individual that uses or relies on our services in order to comply with fraud monitoring and detection obligations, anti-money laundering and know-your-customer obligations and financial reporting obligations that are imposed on us by the operation of law, industry standards, the financial institution, service providers or partners.
   4. Legitimate Business Interest. Although you may not have a direct or contractual relationship with us, we have a legitimate business interest to process your Personal Data provided to us by our Business Customer or Individual Customer to process transactions.

Storing Your Personal Data

1. Security of Personal Data. We make reasonable effort to safeguard and secure your Personal Data. We implement and maintain appropriate technical and organisational security measures:
   1. to prevent unauthorised or unlawful processing of the Personal Data and the accidental loss or destruction of, or damage to, the Personal Data;
   2. to ensure a level of security appropriate to the harm that might result from such unauthorised or unlawful processing or accidental loss, destruction or damage; and the nature of the Personal Data to be protected.
2. Retention of Personal Data. We retain your Personal Data for as long as we are providing the services to our Business Customers and Individual Customers. Even after we stop providing such services, we may be required retain your Personal Data for a specific duration to comply with our legal and regulatory obligations. Once we are no longer required to retain your Personal Data, we will delete it in accordance with our policies and procedures.

Your Rights as a Data Subject

You have the following rights in respect of your Personal Data we process:

1. Right to Access: You may request access to your Personal Data and to request for a copy of your Personal Data.
2. Right to Correct: You may request to correct and/or update your Personal Data which is incorrect, incomplete or outdated.
3. Right to Limit Processing: Under certain conditions, you may request to restrict or limit the processing of your Personal Data. For example, if permitted by laws, you may refuse the sharing of your Personal Data to a third party.
4. Right to Lodge a Complaint: You have the right to lodge a complaint with a competent data protection authority if you consider the processing of your Personal Data has been violated.
5. Right to Erasure: You have the right to request that your Personal Information be deleted or removed from our systems and records.  However, this right only applies in certain circumstances.
6. Right to Withdraw: You may choose to withdraw your consent previously given to us. However, take note that we may not be able to provide or continue to provide services to you if you withdraw your consent. The withdrawal of your consent will also not affect the lawful processing of your Personal Data before we received notice of your withdrawal.
7. Right to Transfer: You may request to transfer your Personal Data to a third party or yourself. We will transfer the Personal Data in a structured, commonly used, machine readable format.
8. If you wish to exercise any of your rights above, you may contact us at [email protected].

Your Marketing Choices

You can opt out from receiving marketing communications from us by clicking on the “unsubscribe” link at the bottom of a Tranglo marketing email and you will be excluded from our newsletter and contacts.

Please note that if you opt-out of receiving marketing-related emails from us, we may still send you transactional or administrative messages.

Update to Our Privacy Notice

We may update or revise our Privacy Notice from time to time without prior notice. We advise you to check our Site for the latest version of the Privacy Notice on a regular basis.

If you are our Business Customer or Individual Customer, we will notify of any update or revision in writing.

Contact Us

If you have any questions about this Privacy Notice, the Personal Data we process, or you would like to exercise one of your rights as a data subject, you may contact us at:

Please allow us reasonable time to respond and effect any change.

If you believe that your right as a data subject has been violated, you may lodge a complaint with a competent data protection authority.

Glossary