Privacy Notice

1. Introduction

Driven Communications Sdn Bhd (“we”, “us”) is committed to the protection of your personal data and your privacy. This Privacy Notice explains how we process your data from the point we collect, use, share and dispose of it, and our security measures to ensure your personal data is protected. In compliance with the Personal Data Protection Act 2010 and its regulations and amendments (“PDPA”), this Privacy Notice applies to any person who provides us with personal data, or whose personal data is otherwise collected, used or processed by or disclosed to us, in connection with the paultan.org used-car classifieds (the “Service”).

2. Cookies and tracking technology

The Service uses cookies and similar technologies for gathering information such as browser type and operating system, counting visitors, understanding how visitors use the Service, and measuring the performance of the Service and of advertising. This includes analytics and advertising tags from third parties (such as Google Analytics, and the Meta, TikTok and X advertising pixels), which may set their own cookies subject to their own privacy policies. A seller login session is maintained with a cookie tied to your account.

3. Personal data we collect

The personal data collected and processed by us includes, but is not limited to:

• your name and, for Pro sellers, your business name;
• your mobile telephone number (which is also your seller login and is displayed as the WhatsApp contact on your listings) and your email address;
• the content of your listings, including vehicle details and photographs;
• records of credit purchases and listing fees (your card details are collected and processed by our payment provider, 2C2P, and are not stored by us);
• your network usage data and other information gathered automatically, including IP address, pages visited and other activities on the Service; and
• any other personal data you provide to us for the purposes below.

4. How we collect it

Directly: when you create a seller account, verify your phone number or email address, publish a listing, purchase credits, contact us, or otherwise make your personal data available to us. Indirectly: from our related companies and service providers in connection with your relationship with us, and from technical data gathered automatically when you use the Service. If you supply us with another person’s personal data, you undertake that you have obtained their consent and made them aware of this Privacy Notice.

5. Why we collect it

We collect and process your personal data for purposes including: providing and operating the Service; registering and administering your seller account; reviewing and publishing your listings and displaying your name and contact number to potential buyers; processing credit purchases and issuing receipts; sending you one-time login and verification codes and account notices (via WhatsApp and email); responding to your queries; preventing, detecting and reporting fraud or crime; complying with legal and regulatory requirements; internal record keeping, research and service improvement; and, in the event of a business sale or re-organisation, transferring data to the relevant parties as part of that exercise. We may also use your contact details to inform you about Service features and updates.

6. Your obligations

You must supply personal data to us that is accurate and current — buyers rely on your name and contact details, and receipts and legal notices are sent to the email you verify. If you do not provide the personal data required, we may be unable to provide the Service to you.

7. Transfer of personal data

Your personal data may be transferred to, stored and processed in a jurisdiction other than Malaysia — in particular, our infrastructure and communications providers (including content-delivery, email and messaging services) may process data outside Malaysia. We take reasonable precautions to ensure that personal data transferred outside Malaysia receives a standard of protection comparable to the PDPA, and such transfer is subject to this Privacy Notice.

8. Disclosure of personal data

Generally, your personal data is kept confidential. We may disclose it to: our parent, subsidiary, associated and related companies; our service providers as necessary to operate the Service — including our payment provider (2C2P), messaging provider (for WhatsApp one-time codes), email delivery provider and hosting/content-delivery providers; advertising platforms, to the extent your listing is syndicated as advertising content (listing content and contact number as displayed publicly, not your account records); our professional advisers; any person to whom we are compelled to disclose under law or in response to a regulator, enforcement agency or court; and such other persons as we may reasonably think necessary for the purposes above. Buyers see your public listing content, your display name, seller type and your WhatsApp contact number — do not list if you are unwilling for that information to be public.

9. Security measures

We make reasonable efforts to implement appropriate technical, physical and procedural security measures, in accordance with relevant laws and industry standards, to protect against unauthorised or unlawful processing of your personal data. Seller accounts use one-time codes rather than stored passwords. You are responsible for the security of the phone number and mailbox used with your account. We shall not be held liable for unauthorised access, interception or loss of personal data beyond our reasonable control.

10. Minors

The seller programme is available only to individuals aged 18 or over. In respect of any personal data of individuals under 18 provided to us, you confirm you are their parent or legal guardian or otherwise authorised to consent on their behalf to the processing of their personal data in accordance with this Privacy Notice.

11. Retention

We retain your personal data only for as long as is relevant for the purposes above, unless a legal, regulatory, tax or accounting obligation requires a longer period. Payment and listing records are retained as required for those purposes. When information is no longer required, we take reasonable steps to ensure it is deleted or destroyed.

12. Your rights

• Withdrawal of consent: you may at any time withdraw your consent to our processing of your personal data, in whole or in part, by written notice to the contact below, subject to a reasonable period for the withdrawal to take effect and to the extent it does not conflict with our other legal obligations. Withdrawing consent required to operate your account will mean closure of the account.
• Limitation of processing: if you do not wish your personal data to be shared as described, or do not wish to receive non-essential communications, inform us in writing at the contact below.
• Access and correction: you may request access to and correction of personal data that is inaccurate, incomplete, misleading or out of date. We reserve the right to charge a reasonable administrative fee for retrieving records, and will inform you of any fee before processing the request. You can also view and update your name, seller type and email in your seller profile at any time.

13. Updates to this notice

We review and update this Privacy Notice from time to time to reflect changes in law and business practice; updates are effective on posting. By continuing to deal with us, you are deemed to have accepted the updated Privacy Notice.

14. Acceptance

By indicating your acceptance of this Privacy Notice (including when creating a seller account), you are deemed to have expressly consented to the processing of your personal data by us for the purposes stated.

15. Exclusion of liability

You acknowledge and agree that we shall not be liable for any claim, loss or damage howsoever arising from any inaccuracy, loss, deletion or modification of data, or in relation to any access or use of information by another party, whether caused by technical failure, interruption, error, omission, delay, viruses or otherwise, and you shall indemnify us against any loss arising from your provision of false or inaccurate personal data.

16. Language

This Privacy Notice is provided in English. A Bahasa Malaysia version may be provided; in the event of conflict, the English version prevails.

17. Contact us

You can contact us regarding the processing of your personal data at:

Legal Department
Driven Communications Sdn Bhd
K3-3A-02, Tower 3, UOA Business Park,
Glenmarie, No. 1, Jalan Pengaturcara U1/51A,
Section U1, 40150 Shah Alam, Selangor, Malaysia.
Telephone: +603-5567 9440
Email: [email protected]