Privacy Policy


By using our website and accepting the Privacy Policy upon registration, you authorized us to use and disclose your personal information in the manner described in this Privacy Policy. Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Contacts permission; Camera permission; Microphone permission; Contact list permission; Approximate location permission (continuous); Cookies; Usage Data; email address; password; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

Personal Data” means information about you such as your name, address, telephone number, email address, your personal preferences, bank account information or any other information that might identify you.

By registering an account with LubyPay or otherwise interacting with services, or by using the LubyPay website (“Website”), you consent to the processing of your Personal Data by LubyPay and all our suppliers, advertising and promotional partners, and other service providers.

The personal data we collect.

Personal Data provided by you. From the point of registration of your account with LubyPay, we will collect and process your personal data. This includes particulars you disclose in our application form or in our LubyPay ecommerce platform.

We collect and use image information, including but not limited to photos and screenshots whereby such images are provided by you to LubyPay. We use this information to enhance user experience, such as displaying user profile photo, product images and so on. By using our app, you consent to the collection and use of image information as described in this policy and confirm that you have collected the relevant consent from the third party should their image is disclosed to us.

Personal Data collected by us. In addition to Personal Data, you provide to LubyPay directly, personal data may be collected from time to time from a variety of sources, including without limitation, from the cookies used by our Website.

What Information Do We Collect ?

  • When you open account with LubyPay, we collect the following information:
  • Full name, date of birth and job title.
  • Contact information including Mobile number and Email address.
  • Profile Image
  • Demographic information such as full address and post code.
  • Device ID
  • Financial information internal transfer details and/or withdrawals to the bank account.
  • For verification purposes we reserve the right to request proof of identification in an offline format.
  • Your IP address and access times will be tracked and stored against your user ID for the dual purposes of preventing fraud and creating an audit trail when using the LubyPay service.
  • Other information relevant to customer surveys and/or offers.

What We do with The Information We Collect?

    We require this information to understand what you need and provide you with a better service, and for the following reasons:
  • Internal record keeping.
  • Process transactions and send notices about your transactions.
  • Provide the services and customer support you request.
  • We may use the information to improve our products and services.
  • We may periodically send promotional e-mail about new products, special offers or other information which we think you may find interesting using the e-mail address which you have provided.
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by e-mail, phone, fax, or mail.
  • We may use the information to customize, measure, and improve our services and the content of our website.
  • Compare information for accuracy and verify it with third parties.
  • Prevent potentially prohibited or illegal activities and enforce our Terms & Conditions.
  • Resolve disputes, collect fees, and troubleshoot problems.

What we use your personal data for

LubyPay only uses and processes your Personal Data for purposes relating to LubyPay’s services and for the other business activities of LubyPay including without limitation:

  • To assess and process your request for our services
  • To carry out market analysis and research, and customer profiling to gauge market trends;
  • Or internal administrative purposes;
  • To send you information, updates or other materials on our products or services, upcoming events or promotions which may interest you; and
  • To provide information to regulatory and governmental authorities or other persons in compliance with its obligations under law.

Disclosure to Third Parties

Save as set out below, LubyPay does not sell or rent, and does not otherwise share your Personal Data with any third party.

LubyPay engages other companies, service providers and individuals to perform certain functions on its behalf and to administer and give effect to commercial transactions. Consequently, LubyPay may provide access to or disclose your Personal Data to such persons as those listed below (not exhaustive):

  • Our business partners (e.g. information technology service providers, insurance providers);
  • Banks and financial institutions (including credit card payment processors);
  • Professional advisors and external auditors;
  • Potential or actual acquirers of the LubyPay business (including their advisers and representatives) because of a potential sale of business, acquisition, merger or re-organisation.
  • Regulatory and governmental authorities to comply with legal and governmental requirements.


LubyPay take appropriate physical, technological, organisational, and administrative security actions to safeguard your Personal Data from unauthorised access, use, and disclosure, depending on the type of Personal Data and how we process it, including, but not limited to:

  • LubyPay uses Secure Socket Layers (SSL) to protect your Personal Data.
  • Account passwords are hashed when stored in our encrypted database.
  • The authenticity of request methods is verified to prevent CSRF (cross-site request forgery) attacks.
  • Two-Factor Authentication (2FA) is required to access to AWS resources.
  • VPN access is required to access to production data and only allow limited people to have access to it.

Your rights to Access and Correction

You can request to see your Personal Data and, if the Personal Data is inaccurate, you can request that LubyPay update it. You may do so by sending an email to us at Please allow us reasonable time to respond and effect any change.

Withdrawing or Limiting Consent

If you choose not to furnish any mandatory Personal Data requested or wish to withdraw your consent or significantly limit the processing of your Personal Data, you agree that LubyPay may be unable to process your Personal Data, and any corresponding services may be curtailed. When you do so, you acknowledge that LubyPay will not be liable for any losses which you suffer because of your own action.

Conflict and Revisions

In the event of any conflict between the English language version and the Bahasa Malaysia version, this English language shall prevail. LubyPay reserves the right to modify, update or amend this Notice from time to time. By continuing to communicate with LubyPay or using LubyPay’s services, you signify your acceptance of such modifications, updates, or amendments.

Disclose Any Information to Outside Parties

  • We do not sell, trade, exchange or otherwise transfer to outside parties your personally identifiable information for any reason without your consent.
  • This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you as banks or credit/debit card processing and verification services. These entities may not use your information for secondary purposes, unless required by law.
  • For transaction volumes over a certain limit, we are legally required to report some personally identifiable information to the authorities.
  • We may also release your information when we believe it is appropriate to comply with the law, enforce our website policies, or protect our rights, property, or safety.

Protection of Your Information

  • LubyPay protects your account information from unauthorized access, use or disclosure.
  • You must enter your login and password each time you want to access your account preferably using virtual keyboard. Be sure to logout when finished using a shared computer and otherwise protect the password used to access the LubyPay services.
  • Never share your account details with anyone. If you are concerned that your password has been compromised, you must change it once you are logged on, or contact our support team

Control of Personal Information

  • If a user’s personally identifiable information changes (such as your phone, e-mail or postal address), or if a user no longer need our service, we provide a way to correct and update that user’s personally identifiable information, as provided to us. This can be done by logging into your account and clicking on the “setting” link. Your phone and postal address can only be changed once in any 3-month period.
  • To close your account, you would need to click on “Close Account” button. However, please understand we can’t completely delete user information because of legal regulatory and technical back up requirements.

Children’s Online Privacy Protection Act Compliance

  • We follow the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 18 years of age.
  • Our website, products and services are all directed to people who are at least 13 years old or older.

Links to Other Websites

  • Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over those other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement.
  • You should exercise caution and look at the privacy statement applicable to the website in question.


  • When you access our website, we track how our website is used and may place small data files called “cookies” on your computer.
  • We send a “session cookie” to your computer when you log into your account. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we don’t need to ask you for your password on each page. Once your logout or close your browser, this cookie expires and no longer has any effect.
  • We also use longer-lasting cookies for other purposes such as to display your e-mail address on our login form, so that you don’t need to retype the e-mail address each time your login to your account.
  • We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser permits but doing so may interfere with your use of our website.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services, or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


We may use third-party Service Providers to monitor and analyse the use of our Service.

CI/CD Tools

We may use third-party Service Providers to automate the development process of our Service.

Behavioural Remarketing

We may use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website.

If you have questions or concerns regarding this privacy policy, you may contact us by using this email address

Privacy Policy