PRIVACY POLICY  
(Malaysia – E-Commerce, Telecommunications & Telematics Services)  
1. Introduction  
GPSina Asia Sdn Bhd (“we,” “us,” “our”) is committed to protecting your personal data  
in accordance with the Personal Data Protection Act 2010 (PDPA), regulations issued by the  
Malaysian Communications and Multimedia Commission (MCMC), and other applicable  
Malaysian laws.  
This Privacy Policy explains how we collect, use, process, store, and protect your personal  
data when you use our:  
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E-commerce platform for purchasing fleet trackers, dashcams, SIM cards, data plans,  
and related services  
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SIM card registration, activation, renewal, reconnection, replacement, and data plan  
management services  
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Customer portal for account management, billing, and telematics monitoring  
Telematics services, including GPS tracking and dashcam data services  
2. Information We Collect  
We may collect and process the following categories of personal data:  
A. Personal Identification & Contact Details  
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Full name  
NRIC number / passport number (for SIM registration and identity verification  
Date of birth  
Billing and installation address  
Email address  
Mobile and contact numbers  
B. Telecommunications Registration Data (MCMC Compliance)  
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SIM card serial number (ICCID)  
Mobile number (MSISDN)  
SIM registration and activation details  
Identity verification documents and records  
SIM status history (activation, suspension, reconnection, termination, replacement)  
C. Telematics & GPS Data  
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Vehicle location data  
Route history and trip records  
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Driving behaviour data (e.g., speed, braking, movement patterns)  
Dashcam system metadata (time, location, device ID)  
Device identifiers linked to vehicles or drivers  
D. Financial, Billing & Transaction Data  
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Payment card details (processed via secure payment gateways)  
Bank account or FPX payment information  
Transaction and invoice history  
Subscription and auto-renewal preferences  
Charges related to:  
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Service renewals  
Reconnection fees  
SIM replacement or re-issuance  
Postal or delivery charges  
Add-on services and data plans  
E. Logistics & Delivery Information  
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Recipient name  
Delivery address  
Contact number for shipment  
Courier tracking details (for SIM or hardware delivery)  
F. Technical & Usage Data  
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IP address  
Login credentials and authentication logs  
Portal activity and access logs  
Device and browser information  
Cookies and session data  
3. How We Use Your Information  
We process your personal data for the following purposes:  
Purpose  
Legal Basis (PDPA)  
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To register, activate, renew, reconnect,  
suspend, or replace your SIM card and data  
plan  
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Performance of contract;  
Legal obligation (MCMC)  
To sell and deliver SIM cards, hardware, and  
related products  
Performance of contract  
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To provide telematics and GPS tracking  
services  
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Consent; Legitimate  
interest  
To manage service lifecycle events (renewals,  
reconnections, SIM replacement, delivery)  
Performance of contract  
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To process payments, recurring billing, and  
service-related charges  
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Performance of contract  
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To manage your customer portal access and  
account  
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Performance of contract  
Legitimate interest  
To send service notifications, renewal  
reminders, billing alerts, and data usage  
updates  
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To comply with MCMC, law enforcement, and  
regulatory requirements  
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Legal obligation  
To improve system security, prevent fraud, and  
ensure service integrity  
Legitimate interest  
4. Data Sharing & Third Parties  
We only share your personal data where necessary, including with:  
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Telecommunications partners for SIM activation, data provisioning, and service  
management  
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Payment service providers (e.g., Stripe, FPX, banks) for transaction processing  
Logistics and courier companies for delivery of SIM cards, devices, or replacement  
hardware  
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Cloud and hosting providers (e.g., AWS, Google Cloud) for secure storage and portal  
operations  
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Installation or technical service partners (where installation is requested)  
MCMC, law enforcement, and government authorities where required by law  
We do not sell or trade your personal data to third parties.  
5. Data Security  
We implement appropriate technical and organizational measures, including:  
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Encryption of data in transit and at rest (SSL/TLS)  
Secure storage of telecommunications and telematics data  
Access controls and role-based permissions  
Audit logging and system monitoring  
Compliance with applicable MCMC security standards for telecommunications data  
6. Data Retention  
We retain personal data only as long as necessary for the purposes stated above or as  
required by law:  
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Telecommunications registration data: As required under MCMC regulations  
SIM lifecycle and billing records: For the duration of service and applicable legal  
retention periods  
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GPS and telematics data: Retained for 60 months unless otherwise agreed or  
required for investigation or legal purposes  
Financial and tax records: Retained for 7 years in accordance with Malaysian tax  
laws  
7. Your Rights Under PDPA  
Subject to legal limitations, you have the right to:  
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Request access to your personal data  
Request correction of inaccurate or incomplete data  
Withdraw consent (where processing is based on consent)  
Request restriction or deletion of data (subject to legal and contractual obligations)  
Opt out of marketing communications  
Requests may be submitted through our customer support channels.  
8. Cookies & Tracking Technologies  
We use cookies and similar technologies for:  
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Session management and secure portal login  
Analytics and system performance monitoring  
Storing user preferences (e.g., language, region)  
You may control cookie settings through your browser, but disabling cookies may affect  
portal functionality.  
9. Updates to This Privacy Policy  
We may update this Privacy Policy to reflect changes in law, regulatory requirements, or our  
services (including SIM, data plan, or telematics offerings). Updated versions will be  
published on our website. Continued use of our services constitutes acceptance of the  
updated policy.  
PART 2: TERMS & CONDITIONS (Malaysia E-Commerce + Services)  
1. Acceptance & Agreement  
By using our website, purchasing products/services, or logging into the portal, you agree to  
these Terms and any applicable MCMC regulations and PDPA requirements.  
2. Eligibility  
You must be:  
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At least 18 years old  
Legally able to enter a binding contract  
The registered user of any SIM card activated (per MCMC rules)  
3. Products & Services Description  
A. Fleet Trackers & Dashcams  
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Sold as hardware; service requires active data plan  
Installation may be done by third-party partners; we are not liable for installation  
issues  
B. SIM Cards & Data Plans  
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Activation subject to MCMC verification  
Data speeds and coverage are as per our telecom partner’s service terms  
Auto-renewal is default unless cancelled 7 days before renewal date  
C. Customer Portal  
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Access is for authorized users only  
You are responsible for login credentials and any activity under your account  
4. SIM Registration (MCMC Compliance)  
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You must provide accurate and complete identification for SIM registration. We  
reserve the right to suspend service if false information is provided.  
5. Telematics & GPS Services  
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Data is provided “as is”; we do not guarantee real-time accuracy  
You are responsible for complying with privacy laws when monitoring  
vehicles/drivers  
6. Payment & Auto-Renewal  
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Recurring charges will continue until cancelled  
Failure to pay may result in service suspension (data, tracking, portal access)  
7. Returns & Refunds  
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Hardware: Return within 14 days if defective (warranty applies)  
SIM/Data plans: No refund once activated, subject to telco partner policies  
Services: No refund for partial months of telematics/data service  
8. Limitation of Liability  
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We are not liable for:  
Service interruptions beyond our control (telco network outages)  
Misuse of telematics data by account holders  
Third-party installation or hardware failure not under warranty  
9. Termination  
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We may suspend or terminate your portal access and services if:  
You breach these Terms  
You provide false registration information  
Illegal activity is suspected  
10. Governing Law & Dispute Resolution  
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These Terms are governed by the laws of Malaysia. Any disputes shall be referred to  
the Malaysian Communications and Multimedia Commission (MCMC) where  
applicable, or settled in the courts of Kuala Lumpur.  
11. Changes to Terms  
We may update these Terms to reflect changes in law or services. Continued use  
after changes constitutes acceptance.  
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