Privacy Policy JayaKaya — We Take Your Data Seriously

1 Introduction

Jayakaya values the privacy of every member who uses our platform. This Privacy Policy details how we manage your personal data — from how it is collected, what it is used for, who it may be shared with in certain circumstances, and how you can exercise control over your own information.

This document applies to all users who access the jayakaya website, the jayakaya mobile app, and all services provided under the jayakaya brand. By registering an account or using any of our services, you agree to the data protection practices described in this document.

2 Personal Data We Collect

Jayakaya collects your personal data through several different channels. Below is a complete table of the types of data we collect and their sources:

We do not collect any sensitive data such as your medical information, political affiliations, or religious beliefs. Only information strictly necessary to operate the jayakaya platform services is collected.

3 How We Use Your Data

The personal data we collect is used for legitimate and limited purposes. jayakaya will not use your data beyond the scope described below without first obtaining your consent:

• Account management — Creates, verifies, and manages your member account, including the KYC process.
• Transaction processing — Processes deposits, withdrawals, and all financial transactions in your account securely and efficiently.
• Customer service — Addresses enquiries, resolves complaints, and provides technical support to you.
• Platform security — Detects and prevents fraud, hacking, money laundering, and other suspicious activities.
• Legal compliance — Fulfils regulatory obligations and reporting requirements to the relevant authorities.
• Service improvements — Analyses usage patterns to enhance the user experience and platform performance.
• Marketing communications — Sends relevant promotional information and special offers, subject to your communication preferences.

4 Legal Basis for Data Processing

Jayakaya processes your personal data on a valid legal basis under Malaysia's Personal Data Protection Act 2010 (PDPA). Each of our data processing activities has a clearly defined legal basis:

• Contract fulfilment — Processing required to provide the services you have requested, including account management and payment processing.
• Legal obligations — Processing required to comply with Malaysian law, including anti-money laundering (AML) and KYC requirements.
• Legitimate interests — Processing for security, fraud prevention, and service improvement purposes that do not unreasonably affect your privacy rights.
• Consent — Processing for marketing communications and other optional purposes that require your explicit consent.

5 Data Sharing with Third Parties

Jayakaya does not sell or rent your personal data to any third party. However, in certain limited situations, we may share your data with the following parties for legitimate operational purposes:

• Payment providers — Banks, digital wallet companies, and payment processors that handle your financial transactions. Data shared is kept to a minimum and used solely for payment processing purposes.
• Technology service providers — Companies providing infrastructure, cloud computing, and cybersecurity services that support our platform operations.
• Regulatory authorities — Government agencies or regulatory bodies with legal authority to request relevant information, including the Malaysian Financial Intelligence Unit (UPEN).
• Identity verification service providers — Third parties that assist in conducting KYC checks and identity document verification.

All third parties we work with are required to comply with strict data protection standards and are prohibited from using your data for any purpose other than those specified in their service agreements with jayakaya.

6 Data Retention Period

Jayakaya retains your personal data only for as long as necessary to fulfil the original purpose of collection or to comply with applicable legal requirements. Our data retention guidelines are as follows:

• Active account data is retained for the duration your account remains active on the jayakaya platform.
• Financial transaction records are retained for a minimum of 7 years from the transaction date in accordance with accounting and anti-money laundering legal requirements.
• KYC data and identity documents are retained for 5 years after account closure or the end of the business relationship.
• Communication logs with the customer support team are retained for 2 years for quality assurance purposes.
• Cookie data and login session data are automatically cleared when the session ends or according to your preference settings.

Once the retention period expires, your data will be securely deleted using methods that ensure it cannot be recovered or accessed again.

7 Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010, you have the following rights regarding your personal data held by jayakaya:

To exercise any of the above rights, you may contact the jayakaya support team via live chat or email. We will process your request within 14 business days from the date it is received.

8 Data Security Measures

Jayakaya continuously invests in the latest security technologies and procedures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. Key security measures we implement include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data such as financial details in the database using the AES-256 algorithm.
• Two-factor authentication (2FA) available for all member accounts for an added layer of security.
• Periodic security audits by independent third parties to identify and patch system vulnerabilities.
• Strict access controls ensure that only authorised personnel can access members' personal data.
• Real-time threat monitoring 24 hours a day, 7 days a week by our cybersecurity team.

9 Cookies & Tracking Technologies

The jayakaya website and app use cookies and similar tracking technologies to enhance the user experience and ensure the platform functions properly. The following are the types of cookies we use:

• Essential cookies — Required for core platform functions such as maintaining your login session. These cookies cannot be disabled.
• Preference cookies — Stores your preference settings such as language and display format for a more personalised experience.
• Analytics cookies — Helps us understand how users interact with the platform for service improvement purposes.
• Security cookies — Used to detect suspicious activity and protect your account from unauthorised access.

You can manage cookie settings through your web browser preferences. Disabling certain cookies may affect the functionality of some parts of the jayakaya platform. We do not use third-party cookies for advertising or marketing purposes without your consent.

10 Children's Privacy

The jayakaya platform is strictly for individuals aged 18 and above. We do not knowingly collect or process personal data of anyone under 18. Should we discover that a minor's data has been collected without our knowledge, we will immediately take steps to delete that data and close the relevant account.

11 Amendments to the Privacy Policy

Jayakaya reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological developments. Any material amendments will be communicated to you via:

• In-platform notifications on jayakaya when you log in to your account.
• An email notification will be sent to your registered email address at least 7 days before the changes take effect.
• Updates to the "Last Updated" date displayed at the top of this document.

Continued use of the jayakaya platform after the effective date of any amendment means you accept the updated Privacy Policy. If you disagree with any changes, you have the right to close your account before the amendment takes effect.

12 Contact Us

If you have any questions, concerns, or complaints regarding how jayakaya handles your personal data, or if you wish to exercise any of your rights as a data subject, our privacy team is ready to assist you.

You can reach us via:

• Support Email: [email protected]
• Live Chat: Available 24/7 on the jayakaya platform
• Response Time: Within 14 business days for privacy-related inquiries