Privacy Policy

Date of Last Revision: January 28, 2022

Compargo Malaysia Sdn. Bhd (“CompareHero”) (“we“, “us” or “our”) is part of the Hyphen Group, a group of companies that provide price comparison services as well as financial services, insurance products, communications and other products and services and across Asia.

The CompareHero.my website (“Website“), including the content, features, tools, data, software and functions made available by us through the Website, our mobile applications and any other websites or applications we operate (unless those websites or applications have posted separate or additional terms of service) (together, the “Services”) have been created to provide information to our visitors (“you” and “your”) about our products and services.

This Privacy Policy explains what information and what Personal Data we collect, why we collect it, how we use and disclose it and how we protect Personal Data in compliance with the Personal Data Protection Act of 2010 (“PDPA”). Please be sure to read this entire Privacy Policy before using our Services. When you use, access or interact with our Services, you are agreeing to our Terms and Conditions and consenting to the practices described in this Privacy Policy with respect to the collection, use and disclosure of your information.

In this Privacy Policy, the term “Personal Data” means any data relating directly or indirectly to a living individual which is capable of being used to identify that individual.

Information We Collect

We collect information about you in three main ways: when you provide it to us, with automatic technologies and when third party sources provide it to us.

While using of our Services (for example, in order to get comparative quotes for personal loans), your Personal Data may be collected or provided by you to us in various ways.

The following are examples (without limitation) of the circumstances in which we collect Personal Data:

• When you subscribe to receive updates from us, we will ask for your email address;
• When you request quotes for certain products, we may ask for information like your age and income, so that we can obtain accurate quotes;
• When you redeem a reward on our Services, we may ask for your name, email address, the product you applied for, your application reference number and/or your application date;
• When you contact us by telephone, we may ask for your name, email address and/or phone number, so that we can contact you regarding your enquiry; and
• When you apply for a product or a service using the application forms on our Services, we will collect information which includes but is not limited to contact details, identification information and financial information; and
• If you want to add a child or family member to your application for a product or service, we may collect that family member’s name and date of birth, so that we can process the application.

The Personal Data we may ask you to provide includes (without limitation):

• name
• address
• email address
• telephone number
• date of birth
• age
• nationality
• any messages if you write to us using the “contact us” form
• your income
• details of the products you are looking for (for example, the size of loan)
• passport number national identity number or other identity copies and/or details (where required for purchasing a product or availing of a service)
• education history
• employment status
• employer or company details
• details of your car (including, without limitation to car make and model, driving and claim history), travel or other personal information relevant to the purchase of car insurance and travel insurance
• financial details about you, including details related to the payment method(s) such as credit card and bank account information (when purchasing a product);
• vehicle registration number
• New/old IC number
• Marital status
• Postal code
• Secondary driver name and NRIC or passport number
• Credit card information (card number, card expiry date; and information related to any of the above.

Most often, the provision of the above data is on a voluntary basis. However, if you do not provide sufficient information to us, third party products and service providers may not be able to provide the requested information, products or services to you.

Automatic Collection of Computer Data

In addition, when you use the Services, we may automatically collect certain data about how you access and interact with our Services which may, when combined with other information about you, constitute Personal Data. Automated technologies, such as our use of ‘cookies’, web beacons and similar technologies, help us achieve our goal of providing you with the best possible service. When you access our Services, our servers will record, or track information sent from the browsers. This can include the following information (without limitation):

• attributes of the equipment or device you are using, such as the operating system, hardware version, device settings, software and device identifiers;
• device locations, including specific geographic locations identified through GPS signals or other means;
• connection information such as the name of your mobile operator, ISP or other service provider, browser type and IP address;
• the website from which you have reached the Services;
• the Website pages viewed;
  details of the products and services on the Services that you look at, information, tools and content available on our Services that you use;
• time spent on the Services;
• links from our Services that you click on;
• quotes you request from our Services;
• your transactions on our Services and details of any payments made by you (including bank account and credit card details and any other account identification information); and
• information related to any of the above.

Our use of cookies enables us to:

• provide you with a more personalized experience on our Services. It allows us to remember you when you revisit our Services. You can also access your previously saved quotes;
• study browsing habits on the Services. The more we understand what products you are interested in, the greater our ability to offer you customized solutions and targeted advertisements and other marketing materials; and
• obtain information regarding the number of visitors to the Services and the pages viewed.

In most cases, cookies are deleted when you close your browser; these are referred to as session cookies. However, persistent cookies stay on your browsing device either until such time as you delete them, or they expire. By using the Services, you consent to us using cookies. Such use of data does not disclose any of your Personal Data, and we will not collect, process or use any of your Personal Data in this regard.

You can alter your computer browser settings to block or delete cookies. If you opt to block or delete cookies of the Services, you may not be able to access certain products or services and this could have an effect on the performance of the Services on your system (for example, banner ads may not display properly).

In some cases, we also use cookies or similar technologies provided by trusted third parties. The Services use a feature of Google Analytics, a widely consumed analytics solution. This setup allows for a more accurate tracking of our users by associating that user with the same ID over various sessions and devices. This approach may combine analytics data with other Personal Data about you that we have collected by our Services. Any such combined data will be treated as Personal Data by us and used in accordance with this Privacy Policy.

We may use features in Google Analytics and Google Display Network, including advertising and remarketing, that allow us to target ads to you and report on demographics and interests. These tools use cookies and other information to show ads based on your past actions on our Services. If you would like to opt out of these features please visit https://www.google.com/settings/ads/.

Information Provided to us by Third‐Party Sources

Finally, when you use the Services, we may also receive information about you from other third parties we have partnered with such as CRAs or third parties we have engaged such as business associates, subcontractors, analytics providers, platform providers and search information providers or, pursuant to your request, from third party providers of our Partners or other sources where permitted by law and not otherwise restricted.

Accuracy and Retention of Personal Data

By providing us with your Personal Data or that of a family member, you warrant that such data is true and accurate, and undertake to notify us as soon as practicable of any change or alteration to the same. Any loss or damage caused to the Services or to the person responsible for the Services or to any third person through the provision of erroneous, inexact or incomplete information will be your exclusive and absolute responsibility. When you give us Personal Data about another person (or persons) such as a family member, you should have the authority to act on such person’s behalf (whether by appointment or by law in your capacity as legal guardian). This includes providing consent to our processing of their Personal Data. If for any reason you are concerned as to whether you are permitted to provide us with another person’s information, please contact us at the email address listed below before sending us anything.

All Personal Data that has been collected from you will only be stored for a duration that is relevant to the purpose for which it was processed and for as long as permissible by applicable law(s).

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for (further detailed in the “What do we use your Information for?” section below), including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

You have the right to request access to and correction of your Personal Data as held by us. Please contact us at hello@comparehero.my at any time if you wish to correct, amend or update your Personal Data. We aim to acknowledge and act upon your request promptly. To help us respond in the most timely and appropriate way, please be as specific as possible in your request or inquiry.

What do we use your Information for?

We use the information we collect about you for our legitimate business interests to operate the Services, to enhance and customize users’ experiences with the Services and to improve and grow our business. Depending on the nature of your relationship with us, we may use your Personal Data for some or all of the following purposes:

• to answer your queries and to communicate with you, for example, providing you with alerts, notifications and recommendations;
• to allow you to access and use our free comparison services and to provide quotes to you;
• to enable you to access online application forms on third party external sites;
• to process applications for Partner Products on your behalf (see below section “Partner Products” for further information);
• to analyze customer behavior, market trends and client demographics so that we can improve our services and to enable us to provide a more personalized service and more relevant communications to you;
• to perform credit scoring analysis or other analytics through our trusted partner(s) in order to improve our services and to provide a more personalized experience to you and other users of our Services;
• to enable us to save your Personal Data so that you do not have to re-enter it each time you request a quote or apply for a product;
• to enable us to store data and manage our business operations efficiently;
• with your consent, for direct marketing purposes (see “Direct Marketing” below);
• to diagnose and prevent service, security or technical issues affecting the Services;
• to monitor, detect and prevent fraud or abuse of the Services;
• to protect the safety, integrity and/or rights of our users or any third party;
• to comply with our legal and regulatory obligations; and
• to enable us to provide services and products related to the above and/or otherwise related to your use of the Services.

In some circumstances we will anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

CRA Consent Notice

Pursuant to the PDPA, the Credit Reporting Agencies Act 2010 (“CRA Act”) and Central Bank of Malaysia Act 2009, by accepting this Privacy Policy and using the Services you grant consent to CompareHero (and its related companies within the CompareAsia Group and their authorized officers) to verify Credit Information (as defined in the CRA Act) and conduct credit/trade checks, CCRIS and DCHEQS checks on you with CTOS Data Systems Sdn Bhd (“CTOS”) and/or to Experian Information Services (Malaysia) Sdn. Bhd (“Experian”) and/or Credit Bureau Malaysia Sdn Bhd.

Pursuant to the CRA Act, we may obtain any Credit Information (as defined in the CRA Act) relating to you from Experian, CTOS, Credit Bureau Malaysia Sdn Bhd, their successors or any source deemed appropriate to verify your credit history (each such a “CRA”) as you and/or any such CRA may deem fit under any applicable law, regulation, guidelines, regulatory requirement or directive in relation to your business transaction with us and/or our Partners for the following purposes (but not limited to) account opening, credit evaluation, credit/account review, credit/account monitoring, debt recovery purposes, scoring solutions, legal documentation and/or action consented to a contract or facility granted. Such consent shall remain applicable as long as you have a business relationship with us or where any dues remain unpaid and outstanding with us or for legal documentation consequent to a contract or facility granted by you.

We may transfer your Personal Data to a CRA, where your Personal Data will be processed for the purposes of conducting identity verification by way of electronic-Know Your Customer (“eKYC”) or otherwise and/or generating your credit score. Where required, we and/or the CRA may transfer your credit information to places outside Malaysia. Your Personal Data will be used, processed and stored in accordance with the CRA’s privacy policy, which is outside of our control. The CRA will share your credit report with us so that the CompareAsia Group can showcase those products best suited to your eligibility. By using our Services, you consent to the use, transfer and disclosure of your Personal Data as set out above.

Partner Products

We save you time by allowing you to apply on our Services for products and services provided by third parties (“Partner Products“). If you apply for a Partner Product via our Services, your Personal Data provided to us, along with any other information requested and provided by you will be transferred to the provider and your application will be processed by that provider. That provider may contact you directly about your application. Your Personal Data will be used, processed and stored in accordance with that provider’s privacy policy, which is outside our control.

How do we Disclose your Information?

We are committed to keeping your Personal Data and other information shared with us confidential. There are, however, certain circumstances in which we may disclose or transfer your Personal Data to certain third parties without further notice to you, as set forth below:

• Related Companies: We may share your Personal Data with our affiliates in the Hyphen Group (subsidiaries/affiliated companies of CompareAsia Group Limited- trading as Hyphen Group) that provide services to or share services with us.
• Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of, or in preparation for, a change of control, merger, acquisition, restructuring, dissolution or similar event, we may disclose or transfer Personal Data to a third party.
• Partners: We may be required to share information with our partners who are financial institutions, banks, brokers, credit institutions, lenders, insurance companies and other money and financial service providers whose products may be displayed on our Services from time to time (“Partners”) or when you have requested the products and/or services our Partners, which requires us to provide your Personal Data to them in a pre-populated form or by API. In order for you to redeem a reward on our Services, we may also need to share those details with the relevant Partner in order to authenticate your reward redemption.
• Agents, Consultants and Related Third Parties: We rely on service providers to help support our business, for example (without limitation) our third-party payment service providers, data hosting and storage providers, IT and analytics service providers, back office support, business consultants, legal service providers and marketing service providers. When we engage another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
• Legal Requirements: We and/or any of the third parties listed above may also be required to disclose your Personal Data to any court, law enforcement body, government department, regulator or industry body of any country where required by the laws of Malaysia or any other jurisdiction, or in response to a lawful request in Malaysia or elsewhere. We may also need to disclose your Personal Data in order to (i) identify, contact or bring legal action against any person who may be causing damage to or interfere with our and/or any third party’s rights or property (whether intentionally or otherwise) and/or (ii) to help with anti-money laundering and counter-terrorist financing requirements of our Partners or other third parties.
  In connection with the purposes set out in this Privacy Policy, your Personal Data may be transferred outside Malaysia.  That means your Personal Data may not be protected to the same or similar level as it would in Malaysia.  However, we will take all reasonable measures to ensure that your data is processed and stored securely, regardless of the country in which it is processed or stored.

In connection with the purposes set out in this Privacy Policy, your Personal Data may be transferred outside Malaysia. That means your Personal Data may not be protected to the same or similar level as it would in Malaysia. However, we will take all reasonable measures to ensure that your data is processed and stored securely, regardless of the country in which it is processed or stored. By using our Services and/or submitting any Personal Data to us, you acknowledge and agree that your Personal Data may be processed in and transferred to jurisdiction(s) other than your country of residence which may have different data protection laws that those in your country.

By using our Services, you consent to the use, transfer and disclosure of your Personal Data as set out above.

Keeping you Updated Regarding our Services & Direct Marketing

After you use our Services, we may use your Personal Data (including your name, address, email address and telephone number) to contact you about news, offers, events, and promotional campaigns in relation to price comparison services and/or financial services, insurance, communications, online content and other products and services that we feature on the Services from time to time. For example, this may include information about credit cards, personal loans, insurance products, etc. We may use other data collected about you, including but not limited to your age, location, income bracket, employment, browsing history, purchases and quotes requested in order to provide materials that are customized and relevant to you. You may opt-out of receiving our newsletter and other direct marketing communications at any time by clicking on the unsubscribe link contained in our email to you.

With your explicit consent, we may also provide your Personal Data (including your name, address, email address and telephone number) to our Partners so that they may contact you with news, offers, events, and promotional campaigns in relation to price comparison services and/or financial services, insurance, communications, online content and other products and services that we feature on the Services from time to time.

We may also share aggregated data, provided your identity will not be disclosed by such sharing, with third parties for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve and adapt our products and services, but please note that, unless permitted or required by law or as otherwise set out in this Privacy Policy, we will not disclose your Personal Data to any third parties without your prior consent.

If you have any questions or concerns about the communications you are receiving from us, you can get in touch with us at any time, free of charge (see “Your Rights” below).

Third‐Party Providers

If you opt to enter into a contract with a third party through our Services, the data you provide to the third party will be transferred to that third party and controlled by the third party in accordance with that third-party provider’s privacy policy. Therefore, you should contact them directly for additional information in relation to their privacy policies and read all policies, terms and conditions before entering a contract. We are not responsible for how third-party providers use your Personal Data.

Data Security

We are fully committed to safeguarding the privacy of our customers, online and otherwise, and the success of our business depends on our ability to maintain the trust of our clients and customers. We apply Defense in Depth approach in securing Personal Data entrusted to us by our customers and continuously improve those measures to address security risks. We use Amazon Web Services, Inc (“AWS”) as our technology infrastructure service provider to power the main core of our Services. Data we collect is stored in data centers operated by AWS which offer best-in-class security. For more information, please visit: https://aws.amazon.com/security/.Despite our security precautions, we cannot fully guarantee the security of your Personal Data because of the inherent risks of data transmission over the internet. At all times, you assume the risks associated with the transmission of your Personal Data over the internet and the possibility of malware present on your device used for our Services. Therefore, you should ensure that you only enter or upload your Personal Data on a secure device within a secure environment.

Consent

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

Use of the Services by Minors

The Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not access or use our Services.

Improving our Service

In order to ensure that the services we offer you continue to meet your requirements; we might ask for your feedback. Any feedback or other information you submit to us will, unless otherwise stated, be used in accordance with this Privacy Policy and our Terms and Conditions.

Your Rights

You have the right to check whether we hold Personal Data about you and to require access or correction of your Personal Data. You can also opt out of receiving direct marketing or promotional communications from us, our affiliates and any of our Partners, at any time. You can unsubscribe from receiving our newsletter at any time by clicking on the unsubscribe link in our emails to you.

If you wish to exercise any of your above-mentioned rights, or you have any inquiries or complaints in respect of your Personal Data, please kindly address your enquiries to:

Email : hello@comparehero.my

Tel: 012-385 0211 (lines are open Monday to Friday 9:00am to 6:00pm)

Address : 50-6-3 & 50-6-3A, Level 3, Wisma UOA Damansara, No. 50, Jalan Dungun, Damansara Heights, 50490 Kuala Lumpur

Changes to this Privacy Policy

We may need to revise or update this Privacy Policy from time to time in order to reflect changes in our Services, our business or applicable law. We reserve the right to modify this Privacy Policy periodically without prior notice. Your continued access or use of the Services after any changes or revisions to this Privacy Policy will be deemed to constitute your agreement with the terms of such revised Privacy Policy. We will always include a last revised date as part of our privacy policy. You may check this page periodically to stay informed of our Privacy Policy.