Privacy Policy

1Introduction

This Privacy Policy explains how Global Bell Sdn. Bhd. (Registration No. 200801031643 (832976-W)) (“GoAnsuran”, “we”, “us”, “our”) collects, uses, discloses, stores and otherwise processes your personal data when you visit www.goansuran.com (the “Website”), apply for or use the GoFlexi Handphone Rental Program (the “Program”), or otherwise interact with us.

We are the data controller responsible for your personal data. We process personal data in accordance with the Personal Data Protection Act 2010 (“PDPA”), as amended by the Personal Data Protection (Amendment) Act 2024, and related regulations, guidelines and circulars issued by the Personal Data Protection Commissioner.

By submitting your personal data to us, applying for the Program, or using the Website, you confirm that you have read and understood this Privacy Policy and consent to the processing of your personal data as described here, including the credit reporting and credit check activities described in Section 7.

Our registered address is Block B, Unit B6-0-9 Oasis Ara Damansara, Jalan PJU 1a/7a, 47301 Petaling Jaya, Selangor, Malaysia.

2Scope

This Privacy Policy applies only to personal data processed by GoAnsuran in connection with the Website and the GoFlexi Program. It does not cover any third-party financing plan or product (for example, instalment plans offered by banks, financial institutions or other financing providers), which are governed by the privacy notices and terms of the relevant third party. Where you are directed to a third party’s website or service, that third party’s privacy practices apply.

3Personal data we collect

Depending on how you interact with us, we may collect and process the following categories of personal data:

• Identity and contact data — full name, NRIC/passport number, date of birth, gender, nationality, residential and mailing address, email address and telephone number.
• Application and verification data — employment details, income information, supporting documents (e.g. payslips, bank statements), photographs or identity verification records, and information you provide to assess your eligibility.
• Credit and financial data — credit history, credit score, CCRIS records, trade references, bankruptcy and litigation status, and other credit information obtained through credit reporting agencies and approved sources (see Section 7).
• Transaction and account data — Program account details, device(s) rented, rental and payment records, deposit information, and account status.
• Device and delivery data — delivery address, courier and tracking information, and device condition or defect reports.
• Technical and usage data — IP address, device and browser type, pages visited, and similar information collected automatically through cookies and similar technologies (see Section 13).
• Communications — records of your enquiries, correspondence and support interactions with us.

Sensitive personal data. Some of the data above (such as financial information and, where applicable, biometric identity-verification data) may constitute sensitive personal data under the PDPA. We process such data only with your explicit consent or where otherwise permitted by law.

4How we collect your personal data

We collect personal data:

• directly from you when you complete an application, create an account, contact us, or use the Website;
• automatically when you browse the Website, through cookies and similar technologies;
• from credit reporting agencies, Bank Negara Malaysia (through CCRIS) and other approved sources, in connection with credit and eligibility assessment (see Section 7); and
• from our partners and service providers (for example, our device partner, courier and payment providers) to the extent necessary to operate the Program.

5Purposes of processing

We process your personal data for the following purposes:

• to assess your eligibility for, and to administer, the GoFlexi Program;
• to open, verify, manage, monitor, evaluate and review your account;
• to conduct credit checks and credit/trade verification (see Section 7);
• to process deposits, rental payments and refunds;
• to arrange delivery, return, replacement and servicing of devices;
• to communicate with you, respond to enquiries and provide customer support;
• for debt recovery and the enforcement of our rights under any contract with you;
• to prepare legal documentation consequent to a contract or facility granted by us;
• to detect, prevent and investigate fraud, misuse and other unlawful activity;
• to comply with applicable laws, regulations and lawful requests by public authorities;
• to operate, maintain, secure and improve the Website and our services; and
• where you have consented, to send you marketing communications (see Section 14).

6Legal basis and your consent

We process your personal data on the basis of your consent and, where applicable, because processing is necessary for the performance of a contract with you, for compliance with a legal obligation, or for our legitimate interests in operating the Program. Providing certain personal data is obligatory in order for us to process your application — if you do not provide it, we may be unable to assess your eligibility or provide the Program to you.

7Credit reporting and credit checks (CCRIS / Credit Reporting Agencies)

As part of your application to, and your participation in, the GoFlexi Program, and as a condition of approval, you provide the following consent and authorisation. This reflects the Consent Authorisation Form you agree to during checkout.

7.1 Background searches and credit checks

You consent to GoAnsuran and its authorised officers conducting any and all background searches relating to you, including searches involving Bank Negara Malaysia (BNM) through its Central Credit Reference Information System (CCRIS) and other approved agencies as permitted under the Credit Reporting Agencies Act 2010 (“CRA Act”), to obtain information relating to your credit worthiness, history and status. This may include verifying your identity, assets, any litigious proceedings, bankruptcy status and trade references, and carrying out any other relevant checks and verifications relating to your application, at any time. Where the applicant is a company, this extends to its directors, shareholders, owners, partners, guarantors, persons providing securities and winding-up status.

7.2 Use of your data

You consent to GoAnsuran collecting, assessing, using, verifying, processing and/or disclosing your data for purposes including: opening of account; credit/account monitoring; debt recovery; credit/account evaluation; credit/account review; legal documentation consequent to a contract or facility granted by GoAnsuran; and any other purpose GoAnsuran deems necessary for the GoFlexi Program.

7.3 Disclosure to Credit Reporting Agencies

You consent to GoAnsuran disclosing and releasing your data to relevant credit reporting agencies registered under the CRA Act and appointed by GoAnsuran (“Credit Reporting Agencies”) — for example, licensed credit reporting agencies in Malaysia such as CTOS Data Systems Sdn Bhd and Experian Information Services (Malaysia) Sdn Bhd.

7.4 Consent given to Credit Reporting Agencies

You further consent to the Credit Reporting Agencies:

• obtaining your CCRIS report/score and/or other credit information from relevant data sources;
• assessing, using and disclosing your data to business entities for bona fide trade checking, at any time and to the extent permitted by applicable laws, regulations and regulatory requirements (in the case of a company, this includes its directors, shareholders, owners, partners, guarantors and persons providing securities);
• sharing your trade information with subscribers of the Credit Reporting Agencies;
• processing your personal data in accordance with the PDPA; and
• storing, hosting and/or retaining your personal data with their affiliates, partners, subsidiaries and unaffiliated third parties, including third-party service providers, whether in Malaysia or other countries.

7.5 Indemnity

You agree to indemnify and hold GoAnsuran and the Credit Reporting Agencies harmless against any and all liability relating to GoAnsuran obtaining and using such data for the purpose of conducting credit and trade checks on you.

7.6 Acknowledgement at checkout

By applying to the Program — including by checking the consent box presented during checkout — you acknowledge and agree to be bound by the terms of the Consent Authorisation Form and this Section 7.

8Disclosure of personal data

We may disclose your personal data to the following classes of third parties, where relevant to the purposes set out above:

• Credit Reporting Agencies and credit information sources, including BNM/CCRIS (see Section 7);
• our device, fulfilment and program partners, including our device partner and any party appointed in connection with the GoFlexi Program;
• courier and logistics providers (for example, GDEX) for delivery and returns;
• payment processors and financial institutions;
• IT, hosting, cloud, communications and other service providers acting on our behalf;
• professional advisers, including legal, accounting and audit advisers;
• debt recovery agents and parties involved in enforcing our rights;
• regulators, law enforcement, courts and government authorities, where required or permitted by law; and
• a successor entity in the event of a merger, acquisition, reorganisation or sale of assets.

We require our service providers (data processors) to process personal data only on our instructions and to maintain appropriate security safeguards.

9Cross-border transfer

Your personal data may be transferred to, stored in, or processed in locations outside Malaysia, including by Credit Reporting Agencies and their affiliates and service providers (see Section 7.4). Where we transfer personal data outside Malaysia, we take reasonable steps to ensure it is afforded a level of protection comparable to that required under the PDPA and consistent with the Commissioner’s cross-border transfer requirements.

10Data security

We implement reasonable physical, technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure, alteration and destruction. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, tax or reporting requirements, and to establish, exercise or defend legal claims. When personal data is no longer required, we take reasonable steps to securely delete, destroy or permanently anonymise it.

12Your rights

Subject to the PDPA and applicable conditions, you have the right to:

• access the personal data we hold about you and request information about how it is processed;
• correct personal data that is inaccurate, incomplete, misleading or out of date;
• withdraw your consent to the processing of your personal data (note that withdrawing consent — including the credit-check consent in Section 7 — may mean we can no longer process your application or provide the Program to you, and does not affect processing already carried out);
• limit the processing of your personal data for direct marketing purposes;
• request data portability, i.e. that your personal data be transmitted to another data controller of your choice, where technically feasible and the data formats are compatible; and
• lodge a complaint with the Personal Data Protection Commissioner.

To exercise any of these rights, contact us using the details in Section 17. We may need to verify your identity before acting on a request, and certain requests may be subject to fees or limitations permitted by law.

13Cookies and similar technologies

The Website uses cookies and similar technologies to operate the site, remember your preferences, analyse traffic and improve your experience. You can manage or disable cookies through your browser settings, although some features of the Website may not function properly if you do so.

14Direct marketing

Where you have consented, we may send you information about our products, services and promotions by email, SMS, telephone or other channels. You may opt out of marketing communications at any time by using the unsubscribe link in our messages or by contacting us. Opting out of marketing does not affect non-marketing communications relating to your account or the Program.

15Data breaches

In the event of a personal data breach that is likely to result in significant harm, we will notify the Personal Data Protection Commissioner and, where required, affected individuals, in accordance with the PDPA and applicable guidelines.

16Children

The Program and Website are intended for individuals aged 18 and above. We do not knowingly collect personal data from persons under 18. If you believe we have collected such data, please contact us so we can take appropriate action.

17Contact us

For any questions, requests or complaints regarding this Privacy Policy or your personal data — including data protection matters — please contact us:

18Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The latest version will be posted on the Website with a revised effective date. Where required by law, we will notify you of material changes. Your continued use of the Website or the Program after changes take effect constitutes acceptance of the updated policy.