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    LEGAL

    Privacy Policy

    Last Updated: December 8, 2025

    Effective Date: December 8, 2025

    Systems R Sdn Bhd (Company Reg: 1661269-U) ("Company," "we," "us," or "our"), operating as Systems Ninjas, respects the privacy of our users ("user" or "you"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website systemsninjas.com (the "Site"), use our mobile application, or engage with our services.

    Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the Site.

    This policy is drafted to comply with the Malaysian Personal Data Protection Act 2010 (PDPA), while also adhering to global standards including the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) to support our international client base.

    1. COLLECTION OF YOUR INFORMATION

    We may collect information about you in a variety of ways. The information we may collect on the Site includes:

    A. Personal Data

    Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you register with the Site or when you choose to participate in various activities related to the Site and our mobile application. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.

    B. Derivative Data

    Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

    • B2B Identity Matching: We utilize Happierleads to match visitor IP addresses with public business registries to identify company names and firmographic data (industry, company size) of visitors to our Site.

    C. Financial Data

    Financial information, such as data related to your payment method (e.g., valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processors (such as Stripe), and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

    D. Mobile Device Data

    Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

    E. Audio, Video, & Biometric Data

    • Video Messaging: If you use video messaging to send us inquiries, we collect the video file and any visual/audio data contained therein.
    • Voice Interactions: If you interact with our AI Voice Agents, we record the audio of the conversation for processing, transcription, and quality assurance.

    F. Loyalty & Reward Data

    If you participate in our digital loyalty programs, we collect data regarding your stamp/point accumulation, redemption history, and the specific digital wallet (Apple Wallet/Google Pay) ID associated with your pass.

    2. ARTIFICIAL INTELLIGENCE (AI) & AUTOMATION DISCLOSURE

    We employ advanced artificial intelligence and automation technologies to deliver our services.

    A. AI Processing & Training

    We use third-party AI models (e.g., OpenAI, Anthropic via middleware) to process text and voice inputs.

    • Data Usage: Content you submit to our AI bots (chat logs, voice transcripts) is processed to generate responses.
    • Training: Anonymized interaction data may be used to fine-tune our models to improve accuracy and user experience.
    • Consent: By initiating a chat or voice call with our automated systems, you explicitly consent to this processing.

    B. Automated Decision Making

    We may use automated logic to segment users (e.g., lead scoring based on your interactions tracked by our CRM). However, we do not make legal or similarly significant decisions based solely on automated processing without human intervention.

    3. USE OF YOUR INFORMATION

    Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site to:

    1. Create and manage your account.
    2. Process payments and refunds.
    3. Deliver Digital Cards: Issue and manage loyalty cards.
    4. Targeted Advertising: Generate a personal profile about you to make future visits to the Site more personalized and serve retargeted ads.
    5. User Experience Analysis: Monitor and analyze usage and trends to improve your experience with the Site.
    6. Notifications: Deliver push notifications regarding updates or new content.
    7. Compile anonymous statistical data and analysis for use internally or with third parties.
    8. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
    9. Request feedback and contact you about your use of the Site.
    10. Resolve disputes and troubleshoot problems.

    4. DISCLOSURE OF YOUR INFORMATION

    We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

    A. Third-Party Service Providers

    We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

    B. Business Transfers

    If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

    C. By Law or to Protect Rights

    If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.

    5. TRACKING TECHNOLOGIES

    A. Cookies and Web Beacons

    We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. When you access the Site, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site.

    B. Website Analytics

    We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Site through the use of first-party cookies and third-party cookies, to, among other things, analyze and track users' use of the Site, determine the popularity of certain content, and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors.

    6. SECURITY OF YOUR INFORMATION

    We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

    7. POLICY FOR CHILDREN

    We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

    8. YOUR GLOBAL PRIVACY RIGHTS

    A. Malaysia (PDPA 2010 Compliance)

    For users in Malaysia, in accordance with the Personal Data Protection Act 2010:

    • Right of Access & Correction: You have the right to request access to and correction of information about you held by us.
    • Withdrawal of Consent: You may withdraw your consent to our processing of your personal data by notice in writing.

    B. California Residents (CCPA/CPRA)

    Do Not Sell My Info: We do not sell your personal data in the traditional sense (for money). However, we may share data with partners for the purpose of retargeting or analytics which may be considered "selling" or "sharing" under CPRA. You may opt-out of this by contacting us.

    C. European Union (GDPR)

    If you are a resident of the European Economic Area (EEA), you have certain data protection rights, including the right to request access, correction, deletion, or transfer of your personal data, and the right to object to or restrict processing. We rely on your consent and our legitimate business interests as the lawful basis for processing your data.

    9. INTERNATIONAL DATA TRANSFERS

    Systems R Sdn Bhd is based in Malaysia. If you access the Site from the United States, Europe, or any other region of the world with laws or other requirements governing personal data collection, use, or disclosure that differ from applicable laws in Malaysia, then through your continued use of the Site, you are transferring your data to Malaysia and the United States, and you explicitly consent to have your data transferred to and processed in these jurisdictions.

    10. CONTACT US

    If you have questions or comments about this Privacy Policy, please contact us at:

    Systems R Sdn Bhd (1661269-U)
    W105, West Wing Metropolitan Square,
    No. 2, Jalan PJU 8/1, Bandar Damansara Perdana,
    47820 Petaling Jaya, Selangor, Malaysia
    Email: info@systemsninjas.com
    Phone: +6011-37260706