EZ Money Privacy Policy
(Any reference to EZ Money /We / Our / Ours /Us shall be deemed to refer to EZ Money Sdn Bhd)

(Any reference to you shall be deemed to refer to the customer, the customer’s authorized representative(s), the customer’s beneficiary(ies) and/or the beneficial owner(s) of the customer’s transactions)

EZ Money is committed to the safeguarding and protecting of personal data and privacy. In accordance with this, we will only collect, process and share your personal data in compliance with the law (including but not limited to the Personal Data Protection Act (PDPA) 2010, the Data Privacy Act (DPA) 2012 and all other applicable data protection or privacy laws and regulations).

This Privacy Policy explains in detail what personal data we collect, how we collect, who we disclose it to and for what purpose and scope we process your personal data. This Privacy Policy also sets out your rights including how to access and update your personal data which is being held with EZ Money.

For the avoidance of doubt, this Privacy Policy is applicable to:
(a) all customers of EZ Money, irrespective of whether the customer is a person, entity or otherwise;
(b) any other person, entity or otherwise who is not a customer of EZ Money but whose data is required to be collected by EZ Money by reason of, or incidental to, the provision of any remittance/business payment and/or currency exchange services by EZ Money to its customers, including but not limited to the authorized representative(s) of the customer, the beneficiary(ies) of the customer and/or beneficial owner(s) of the customer’s transaction(s).

1. We shall collect personal data and information (“Personal Data”) from you from time to time for the purposes outlined below:
   a) the provision of remittance/business payment and/or currency exchange services and the approval, management, administering, processing and/or effecting of any remittance/business payment and/or currency exchange services you have engaged with us to conduct;
   b) conducting sanctions, politically exposed persons and internal blocklist screenings as part of our compliance with regulatory and/or foreign counterparty, service provider, correspondent agent, trade partner, currency wholesaler, vendor, supplier and/or partner requirements;
   c) sharing and disclosing your data among our subsidiaries, branches, foreign counterparties, service providers, correspondent agents, trade partners, currency wholesalers, vendors, contractors, partners, suppliers, agents, sub-agents, employees, personnel, directors, shareholders, advisers and representatives as required in order to process and effect any remittance/business payment and/or currency exchange services you have engaged with us to conduct;
   d) updating and maintaining our customer and transaction database and records;
   e) creating and maintaining EZ Money’s risk related models and/or any purpose related to risk management functions;
   f) developing other remittance/business payment and/or currency exchange products and services for our customers’ use (including but not limited to market research, surveys and statistical analysis with the aim of improving our products and services;
   g) for marketing and promotional purposes, including but not limited to reward, loyalty or privilege programs;
   h) for fraud or crime prevention and investigation, transaction disputes, data analytics and audit purposes;
   i) for conducting financial crime risk management activity and the investigating, reporting and/or otherwise preventing of fraud, money launder, terrorism financing and criminal activities in general;
   j) meeting obligations, requirements and/or arrangements of EZ Money and its branches, agents, sub-agents and subsidiaries to comply with or in connection with:
   i) any law, regulation, judgement, court order, voluntary code and/or sanctions regime within or outside Malaysia existing currently and in the future;
   ii) any guidelines, guidance or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Malaysia existing currently and in the future and any international guidance, internal policies or procedures; and
   iii) any present or future contractual or other commitment with local or foreign legal, regulatory, judicial, administrative, public or law enforcement body, or governmental, tax, revenue, monetary, securities or futures exchange, court, central bank or other authorities, or self-regulatory or industry bodies or                associations of financial service providers or any of their agents with jurisdiction that is assumed by, imposed on or applicable to EZ Money and its branches, agents, sub-agents and subsidiaries;
   k) complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information between EZ Money and its subsidiaries, branches, foreign counterparties, service providers, correspondent agents, trade partners, currency wholesalers, vendors, contractors, partners, suppliers, agents, sub-agents, employees, personnel, directors, shareholders, advisers and representatives and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
   l) conducting any action to meet the obligations of EZ Money and its subsidiaries, branches, foreign counterparties, service providers, correspondent agents, trade partners, currency wholesalers, vendors, contractors, partners, suppliers, agents, sub-agents, employees, personnel, directors, shareholders, advisers and representatives to comply with any and all laws, international guidance or regulatory requests relating to or in connection with the detection, investigation and prevention of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions and/or any acts or attempts to circumvent or violate any laws relating to these matters;
   m) meeting any obligations of EZ Money and its subsidiaries, branches, foreign counterparties, service providers, correspondent agents, trade partners, currency wholesalers, vendors, contractors, partners, suppliers, agents, sub-agents, employees, personnel, directors, shareholders, advisers and representatives to comply with any demand or request from relevant regulatory authorities;
   n) for any purpose required by law or regulation;
   o) for the purpose of enforcing EZ Money’s legal rights and/or obtaining legal advice and/or any legal process (whether by way of judicial proceedings or any other form of proceedings recognised in law) initiated by or served on EZ Money and its subsidiaries, branches, foreign counterparties, service providers, correspondent agents, trade partners, currency wholesalers, vendors, contractors, partners, suppliers, agents, sub-agents, employees, personnel, directors, shareholders, advisers and representatives;
   p) for making enquiries or investigations as to whether or not the customer or person whose data is collected, used and/or processed by EZ Money and its subsidiaries, branches, foreign counterparties, service providers, correspondent agents, trade partners, currency wholesalers, vendors, contractors, partners, suppliers, agents, sub-agents, employees, personnel, directors, shareholders, advisers and representatives is actually a sanctioned person, or is otherwise howsoever related to, or associated with, a sanctioned person or entity; and also for the reporting or the taking of any remedial or preventive action in relation thereto;
   q) for all ancillary purposes relating to the provision of remittance/business payment and/or currency exchange services including the provision of computer, telecommunications and technology services;
   r) for business planning, decision making and/or internal operational requirements of EZ Money and its subsidiaries, branches, foreign counterparties, service providers, correspondent agents, trade partners, currency wholesalers, vendors, contractors, partners, suppliers, agents, sub-agents, employees, personnel, directors, shareholders, advisers and representatives (including, without limitation, financial and risk analysis and management, system or product development and planning, reporting, audit and administrative purposes);
   s) maintaining the relationship between EZ Money and its subsidiaries, branches, foreign counterparties, service providers, correspondent agents, trade partners, currency wholesalers, vendors, contractors, partners, suppliers, agents, sub-agents, employees, personnel, directors, shareholders, advisers and representatives and the customer; and/or
   t) any activity related to or incidental to any of the aforementioned purposes.
2. Such Personal Data (including sensitive data) may include information concerning your personal details (such as name, age, gender, identity card number, passport number, date of birth, education, nationality and citizenship), contact details (such as residential address, email and phone numbers), family information (such as marital status, name of spouse or child or immediate family), occupation details (such as employer name, income, job title, employer’s contact information and address), banking details (including bank account name, bank account number and bank name), company details (such as business details, financial statement and information, beneficial owner, shareholder and director details, tax details, business registration documents, board resolutions and business transaction documentation) and any other information which EZ Money may require to process your remittance/business payment and/or currency exchange transaction, including but not limited to the personal details, contact details, family information, occupation details and banking details of your beneficiary and/or the beneficial owner of your remittance/business payment and/or currency exchange transaction. Should you appoint an authorized representative to conduct your remittance/business payment and/or currency exchange transaction, EZ Money will also require the Personal Data outlined above to be provided. In addition, EZ Money may from time-to-time request for certain other Personal Data that EZ Money may require to process your transaction and/or for the purposes of reporting to Bank Negara Malaysia and other relevant regulatory authorities.
3. Failure to supply such Personal Data as above and/or withdrawing consent for EZ Money to process the same may result in EZ Money being unable to provide you with remittance/business payment and/or currency exchange services.
4. Personal Data collected and held by EZ Money and its subsidiaries, branches, foreign counterparties, service providers, correspondent agents, trade partners, currency wholesalers, vendors, contractors, partners, suppliers, agents, sub-agents, employees, personnel, directors, shareholders, advisers and representatives in relation to our customers will be kept confidential but may, as necessary, be provided or disclosed to any and all applicable governments, regulatory authorities and/or law enforcement authorities (wherever located, whether within or outside Malaysia, including in jurisdictions which do not have data protection laws that provide the same level of protection as Malaysia) for the Purposes set out in paragraph 1 (who may also subsequently process, transfer and disclose such data for the purposes set out in paragraph 1) subject at all times to any applicable laws (including regulations, standards, industry code of practice, guidelines, obligations and/or directives from any regulatory authorities).
5. Whether it is processed in Malaysia or overseas, in accordance with data protection legislation, all our customer’s data will be protected by a strict code of secrecy and security that may include encryption. We require all of our subsidiaries, branches, foreign counterparties, service providers, correspondent agents, trade partners, currency wholesalers, vendors, contractors, partners, suppliers, agents, sub-agents, employees, personnel, directors, shareholders, advisers and representatives and any other third parties who carry out any work on EZ Money’s behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information. However, we are obligated to disclose your Personal Data if legally compelled to do so by any laws.
6. We will take all practicable steps to ensure that your information will not be kept longer than necessary and in line with our data retention policy. We may need to keep your information for longer where we need the information to comply with regulatory or legal requirements, help detect or prevent fraud and financial crime, answer requests from regulators etc. If we no longer need to keep your Personal Data, we may destroy, delete or anonymize it sooner in accordance with EZ Money’s internal policies and procedures.
7. Under and in accordance with the provisions of the PDPA and the Code of Practice approved and issued under the PDPA, you may:
   a) check whether EZ Money holds Personal Data about you and seek access to such Personal Data;
   b) request for EZ Money to correct any Personal Data relating to you which is inaccurate; and
   c) request clarification on EZ Money’s policies and practices in relation to Personal Data and be informed of the kind of Personal Data held by EZ Money;
8. Under and in accordance with the provisions of the DPA and its Implementing Rules and Regulations, you may:
   a) request to be informed/notified of the identity of the personal information controllers or personal information processors that will be given access to your Personal Data;
   b) request to be informed/notified of the purpose of the Personal Data sharing/processing;
   c) request to be informed/notified of the categories of the Personal Data which will be accessed;
   d) request to be informed/notified of the intended recipients or categories of recipients of your Personal Data;
   e) request to be informed/notified of the existence of your rights, including the right to access and correct and the right to object to use of your Personal Data; and
   f) request to be informed/notified of all other information which sufficiently notifies you of the nature and extent of data sharing and the manner of processing your Personal Data.
9. In accordance with the terms of the PDPA, EZ Money has the right to charge a fee for the processing of any Personal Data access you request.
10. You may request for access to Personal Data, correction of Personal Data and types of Personal Data held by EZ Money. This request should be made in person via any of EZ Money’s branches. You will be asked to complete a Personal Data Access/Correction Form and a fee is chargeable as provided in PDPA.
11. Your continued usage of EZ Money services (remittance/business payment, currency exchange or otherwise) is deemed consent for EZ Money to collect, process and store your Personal Data in accordance with the above. You may visit any EZ Money branch to withdraw your consent at any time however please note that failure to consent to the above may result in EZ Money being unable to provide you with remittance/business payment and/or currency exchange services. Our processing of your Personal Data is always subject to any applicable laws (including regulations, standards, industry code of practice, guidelines, obligations and/or directives from any regulatory authorities).
12. If you have any queries relating to EZ Money’s Privacy Policy, or wish to report misuse or suspected misuse of your Personal Data, you may contact csd@ezmoneyexpress.com.my.
13. EZ Money reserves the right to amend its Privacy Policy at any time and shall place notice of such amendments on EZ Money’s website at www.ezmoneyexpress.com.my or EZ Money’s branches or via any other mode EZ Money deems suitable.
14. Nothing in EZ Money’s Privacy Notice shall limit the rights of customers or EZ Money under the Personal Data Protection Act 2010.
15. If you are reading this as a partner or on behalf of a body corporate, company, organization or business enterprise which is a customer of EZ Money, the giving of this Privacy Policy addressed to the body corporate or business enterprise shall be deemed as notice given to all the partners or office-bearers (as the case may be) of such customer whose data are collected and/or processed by EZ Money for the purposes as stated herein. In this regard, the customer warrants that the customer has obtained the consent of all such individuals to the provision of their data to EZ Money for the foregoing purposes and for disclosure to such parties as stipulated above and the customer undertakes to extend a copy of this Privacy Policy to all such individuals, which expression shall include all such existing and new partners or office-bearers (as the case may be) of the customer from time to time.
16. Aside from customers, this Privacy Policy shall also apply (as the context shall require) in relation to the usage, processing and disclosure of the data of any other individual who is not a customer but whose data is required to be collected by EZ Money by reason of, or incidental to, the provision of any services by EZ Money to its customers, including but not limited to the authorized representative(s) of the customer, the beneficiary(ies) of the customer and/or beneficial owner(s) of the customer’s transaction(s). In this regard, the customer confirms and warrants that the customer (a) has obtained the consent of such individuals to the provision of such data to EZ Money for the foregoing purposes and for disclosure to such parties as stipulated above; and (b) has informed such individuals that EZ Money is not required to obtain any consent from such individuals for their Personal Data.