1. Introduction
The Liulian Tech Sdn. Bhd. ("we", "our", or "us") is committed to protecting the privacy of our users ("you" or "your") and handling your personal data with transparency and care. This Privacy Policy explains how we collect, use, share, and protect your personal data when you use our mobile recharge application, website, and services (collectively, the "Services").
We process your personal data in accordance with the Malaysian Personal Data Protection Act 2010 (PDPA) and its subsidiary legislation, including the Personal Data Protection Regulations 2013.
2. Data We Collect
We collect the following categories of data:
a. Personal Information
- Full name
- Email address
- Mobile number
- Country of residence
- Date of birth
- Gender
- Profile photo (if uploaded)
b. Transaction Information
- Recharge history
- Order IDs
- Selected telecom operator
- Payment and refund records (excluding sensitive card information)
c. Technical & Usage Information
- IP address
- Device identifiers (e.g., IMEI, UUID)
- Browser type and version
- Operating system
- Language settings
- App usage statistics and logs
d. Location Data
- Approximate geolocation, if permitted by device settings
e. Cookies and Tracking Technologies (for web users)
We use cookies and similar technologies to enhance functionality, analyze usage, and improve user experience. See our separate Cookie Policy for more details.
3. Purpose of Data Processing
We use your personal data for the following purposes:
| Purpose | Legal Basis |
|---|---|
| To register and manage user accounts | Contractual necessity |
| To process mobile recharges and payments | Contractual necessity |
| To issue refunds and track orders | Contractual necessity |
| To send important service notifications | Legitimate interest |
| To respond to user inquiries and support tickets | Contractual necessity |
| To improve app functionality and user experience | Legitimate interest |
| To prevent fraud and abuse | Legitimate interest / Legal obligation |
| To comply with legal and tax obligations | Legal obligation |
| To send marketing communications (with your consent) | Consent |
4. Data Sharing and Disclosure
We do not sell your personal data.
We may share your data with:
- Payment service providers (e.g., Stripe, PayPal, etc.)
- Telecom operators and recharge partners for fulfillment
- Cloud hosting and infrastructure providers
- Analytics providers (e.g., Google Analytics)
- Customer support tools
- Regulators, legal authorities, or courts, when required by law or to protect legal rights
All third parties are contractually bound to comply with data protection obligations consistent with this policy.
5. International Transfers
As we operate globally, your data may be processed or stored in jurisdictions outside your country of residence, including in the European Union, United States, and Hong Kong. We ensure that such transfers are safeguarded by:
- Adequacy decisions, or
- Standard Contractual Clauses (SCCs), or
- Other lawful transfer mechanisms under applicable law
6. Data Retention
We retain your personal data only as long as necessary:
| Data Type | Retention Period |
|---|---|
| Account & profile data | While account is active + up to 3 years after closure |
| Payment & transaction records | 5 years (for legal and accounting compliance) |
| Communication logs | 2 years |
| Cookies & usage logs | As per Cookie Policy (usually 13 months or less) |
Upon expiration of retention, we securely delete or anonymize data.
7. Data Security
We implement industry-standard security safeguards:
- TLS/SSL encryption on all communications
- Encrypted storage of sensitive data
- Restricted server access and secure authentication mechanisms
- Regular security audits and threat assessments
Despite these measures, no system is 100% secure. Users are responsible for maintaining the confidentiality of their account credentials.
8. Your Rights
Depending on your jurisdiction, you may have the right to:
- Access your personal data
- Rectify inaccurate or incomplete data
- Delete your personal data (right to be forgotten)
- Restrict or object to data processing
- Withdraw consent (for marketing, cookies, etc.)
- Request data portability
- Lodge a complaint with a data protection authority
To exercise these rights, please email: support@liuliantech.com
We will respond within legally required time frames (usually 30 days).
9. Children's Privacy
Our Services are not directed to children under the age of 13 (or under 16 where required by law). We do not knowingly collect data from children. If you believe we have collected such data, contact us immediately to request deletion.
10. Automated Decision-Making
We do not use your personal data for automated decision-making or profiling that produces legal effects concerning you.
11. Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices or legal obligations. Material changes will be communicated via email or in-app notifications. The latest version will always be available in the app and on our website.
12. Contact Us
For questions, complaints, or requests related to this Privacy Policy:
We may also disclose personal data when we suspect or identify usage involving criminal behavior, such as ransom settlements, extortion, or distribution of exploitative content. In such cases, we may report the matter to appropriate law enforcement agencies in accordance with applicable laws. support@liuliantech.com.