Sabypay (“Sabypay“, “us” or “we“) is committed to protecting and respecting your privacy. This policy (together with our Terms of Use) sets out how Sabypay will process and use any personal data we collect from you, or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will handle it. 

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By visiting “Sabypay.com” (“Platform“) and/or accessing any of the products or services available on our Platform, you accept and consent to the practices described in this policy. You acknowledge that we are acting as a data intermediary As defined in the Personal Data Protection Act 2022 (“PDPA”), as the same may be amended from time to time in connection with the provision of services on our Platform for our customers, and on the instructions of your employer (“Customer“). 

 

​Personal data 
1.    “personal data” means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access. 
2.    We will collect and process personal data about yourself that you provide us through our Platform, e-mail or otherwise. Such information may include your name, address, e-mail address, telephone number, national identification number, bank account number and other financial information, internet protocol address used to connect your device to the Internet etc. 

 

Collection, use and disclosure of your personal data 
1.    We may collect and use your personal data in the following ways: 
(a)   to carry out our obligations arising from any agreements entered into between us and our Customer, and to provide you with the information and updates that you request from us; 
(b)  to administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and 
(c)    as part of our efforts to keep our Platform safe and secure. 
2.    You agree that we may disclose your personal data: 
(a)   To any member of our group, including our affiliated companies;

(b)  To selected third parties including business partners, suppliers and  sub-contractors for the performance of any agreement we enter into with them or you; 
(c)   To third parties in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets and/or (ii) if Sabypay or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be part of the assets transferred to such third party; and 
(d)     If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or other agreements; or to protect the rights, property, or safety of Sabypay, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 

 

Where we store your personal data 
1.    We engage commercial cloud storage providers to store your personal data. Therefore, your personal data may be transferred to and stored in different jurisdictions and may also be processed by staff operating within the various countries who work for us or for one of our contractors. By submitting your personal data, you agree to this transfer, storing or processing. 
2.    We will take commercially reasonable steps to ensure that your personal data is handled securely and in accordance with this privacy policy and the relevant privacy laws, but are unable to guarantee the secure transmission of information via the internet in light of the inherent risks. 

 

Withdrawal of consent 
1.    You must contact the relevant Customer (i.e. your employer) directly to amend any earlier consent that you may have given, to check and/or to correct your personal data withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed. In the event that you require any further clarification, you may contact us via email to our Data Protection Officer at the contact details provided below. We will endeavor to process your query within 10 business days from the day of receipt of your query. 

 

Access to and correction of personal data 
1.    You may access the Platform to make the relevant correction of errors or omissions in personal data which we hold about you. 
2.    If we are unable to respond to your requests within 30 days after receipt of your request, we will inform you in writing within 30 days of the time by which we will be able to respond to the request.

3.   If you require access to personal data or information about the ways in which your personal data has been disclosed or use which is not readily available on the Platform, you must contact the Customer (i.e. your employer) directly. 

 

Retention of personal data 
1.    Notwithstanding the termination of your account or access to the Platform, Sabypay may retain archived copies of content containing personal data for as long as it is required by law or for other legitimate business purposes. 

 

Other Platforms 
1.    Our Platform may, from time to time, contain links to and from the websites and/or platforms of our partner networks, advertisers, affiliates and third party service providers (“Third Party Sites”). If you follow a link to any of these Third Party Sites, please note that these Third Party Sites have their own privacy policies and that we do not accept any responsibility or liability for your engagement with these Third Party Sites and/or how they manage your personal data. Please check the individual privacy policies of these Third Party Sites for more information on how your personal data will be managed. 

 

Changes to our privacy policy 
1.    We reserve the right to amend this privacy policy at any time without any prior notice. You agree that it is your responsibility to check periodically for any updates or changes to our privacy policy. 

 

Contact Information 
1.     Our Data Protection Officer is Andy Lim. We welcome any questions, comments and requests regarding this privacy policy. Please address them to our Data Protection Officer using the contact details below: Name: Andy Lim