Last updated: 2026-10-10 Version: v1.8
This Privacy Policy explains how TELEBORT AI STUDIO PLT (LLP0046066-LGN) ("Telebort", "we", "us", "our") collects, uses, discloses, and protects personal data in connection with the GetPay service, accessible at https://getpay.cc (the "Service").
This Policy is issued pursuant to the Personal Data Protection Act 2010 ("PDPA") of Malaysia. Telebort is the data controller for personal data processed in connection with the Service.
1. Scope
1.1 This Policy applies to personal data we collect about: (a) users who register for and use the Service ("Customers"); (b) end users whose data Customers process through the Service (e.g., your customers, suppliers, employees — "Customer Data Subjects"); (c) visitors to https://getpay.cc; (d) people who submit a claim to a listing in our public business directory (section 2.7), businesses and practitioners shown in that directory (section 2.8), and sellers who are invited to, apply for, or have a listing in our seller showcase (section 2.9); (e) people who chat with a store through its GetPay storekeeper: the chat on a store's GetPay page, the chat on a store's own website, or the demo store (section 2.10); (f) people who use GetPay to keep track of their purchases, follow stores, wave at stores or read stores' updates (section 2.11).
1.2 Where you process personal data of Customer Data Subjects through the Service, you (the Customer) are the data controller and we act as a data processor on your behalf. The terms of that processing are described in our standard Data Processing Agreement.
1.3 We bill GetPay subscriptions, AI top-up packs and usage charges through GetPay's own billing features, run in our own GetPay workspace ("self-billing"). For this, your workspace is recorded as a customer in our workspace, and we use your workspace's usage records (for example, documents issued, AI credits used, employees paid in a month, and amounts billed through the billing layer) to work out your plan and charges.
2. Personal Data We Collect
We collect the following categories of personal data:
2.1 Account and Identity Data
- Full name, email address, phone number, business name, position
- Authentication credentials (hashed; we never see your password in plain text)
- Identity verification information (where required for compliance with anti-money-laundering law)
2.2 Billing and Payment Data
- Billing name and address
- Payment method details (processed by Stripe, our payment processor for subscriptions and AI top-up packs; we do not store card numbers)
- Transaction history and invoice records
- Usage records of your workspace used to calculate your charges (clause 1.3)
2.3 Service Usage Data
- IP address, browser type, device identifiers, operating system
- Pages viewed, features used, click streams, session duration
- Error logs, performance metrics
2.4 Customer-Uploaded Data
- Accounting records, invoices, bills, bank transactions, customer/supplier records, journal entries
- Documents you upload (receipts, PDFs, contracts)
- Any personal data of third parties (your customers, suppliers, employees) that you choose to enter into the Service — for which you are the data controller
2.5 Communication Data
- Support tickets, chat messages, emails to our team
- Survey responses, feedback
2.6 Cookies and Similar Technologies
- Strictly necessary cookies (session management, security, and the storekeeper chat cookies in clause 9.4)
- Analytics and error-monitoring tools (PostHog and Sentry), which start when you first visit — we do not currently ask for consent to these
- See section 9 for details
2.7 Directory Claims
If you claim a listing in our public business directory, we collect:
- Your name, the SSM registration number you state for the business, and your role (the listed person yourself, a director or partner, the company secretary, or an authorised representative)
- The WhatsApp number and/or email address you supply
- A copy of a MyKad or SSM registration certificate that you upload to support the claim
An automated AI vision model reads the uploaded document and extracts the names and, for a MyKad, the IC number printed on it, and compares the name with the name you gave. No claim is approved without review by a member of our team; a claim whose document does not match may be rejected automatically. If your claim is approved, the WhatsApp number and/or email address you supplied is published on the listing until you withdraw your consent. The uploaded document is not published.
2.8 Public Directory Listings
We publish a directory of businesses and practitioners at https://getpay.cc/directories. A listing may show business information and, once a claim is approved, the contact details supplied by the claimant (section 2.7). If information about you or your business in a listing is wrong, or you want a listing removed, use Report an issue on the listing page or email studio.telebort@gmail.com. Our seller showcase at https://getpay.cc/directories/sellers is part of the directory and is covered by section 2.9.
2.9 Seller Listings and Invitations
We publish a showcase of Malaysian online sellers at https://getpay.cc/directories/sellers. A seller listing is created only for a seller who has agreed to it: either you told us you would like one and we sent you an invitation, or you applied yourself from your GetPay account. Nothing is published until you have claimed the listing, reviewed it, and a member of our team has approved it against our published criteria.
If we send you an invitation, we collect and keep:
- The email address we invite (if you trade as a sole proprietor, this may identify you), and the status of the invitation (sent, claimed, declined or expired)
- A record of when, how and in what words you agreed to be invited (the "consent evidence"), and where we found your business (for example a public shop page on a shopping platform or on your own website, or a web search) — the invitation email tells you which
- The business name, and any public shop links, that we prepared for your draft listing
If you claim or apply for a listing, we also collect what you enter:
- Business name, state and city, a short description, a logo, links to your shops on third-party platforms or on your own website, and your product categories — these are published on the listing once approved
- A contact email address and/or WhatsApp number, if you supply them — these are not shown on the listing page; they are shown only to a signed-in visitor who uses the sign-in reveal, and you may withdraw them at any time
- Optionally, your SSM registration number — this is kept private, is never published, and is used only by our reviewers
When you apply for a listing from your GetPay account, we also keep a short application log entry: your workspace (company) identifier, the unique identifier of the user who applied, and the time. It is used only to limit how many seller applications one workspace can submit (abuse and rate-limit control), it is deleted at most 90 days after the application, and it is not published. Deleting an application does not remove its log entry, otherwise the limit could be avoided; a daily automated clean-up deletes every entry older than 90 days (clause 7.2).
Each invitation email contains one-click links to decline or unsubscribe. They are signed, so they keep working even if we later send you another invitation, or the draft or invitation record has already been deleted; if a link cannot be verified we say so and you can reply to the email or write to studio.telebort@gmail.com and we will stop. If you decline, unsubscribe or ask us to stop, we keep a one-way entry for your email address (or its domain): a code made with a secret key that only we hold, so that the address cannot be read back from the code and cannot be confirmed by guessing it. We keep that entry so that we do not invite you again, and we delete the rest of the invitation record as set out in clause 7.2. You can ask to see, correct or delete what we hold about you at any time (section 10); the invitation email says how. You can hide or delete a listing you hold at any time from your account settings; deleting it withdraws your consent and removes the listing and the contact details you supplied. Invitation emails are sent through Resend (clause 5.1). The contact details you supply are shown only through the sign-in reveal.
Storekeeper
Clause 2.10. A store that uses GetPay can give its customers an AI storekeeper: a chat on the store's GetPay page (getpay.cc/c/…), a chat bubble on the store's own website, or our demo store at https://getpay.cc/seller-app. This clause explains what happens to your data when you use one. The store chooses to offer the chat, so the store is the data controller for its customers' chats and we are its data processor (clause 12.3). Replies are written by an AI and can be wrong.
What is collected
- The messages you type and the replies you get, with the time, kept together as one conversation. You do not need an account, and you do not have to give your name.
- Which door you came through (the store's page, a website chat, or the demo) and, if the link you followed carried a tag such as
?src=instagram, where it came from (Instagram, WhatsApp, a QR code, a website, or another source). - A random conversation identifier, kept in a cookie on your device so the conversation continues for up to 7 days (clause 9.4).
- If you choose to verify your email, which is needed before the chat will show your orders, give you a pay link, take an order or tell you your loyalty balance: the email address you enter and, if you give one, a name. You type them into a card in the chat, not into the message box, and we email you a six-digit code. We keep the code only as a salted hash; it is valid for 10 minutes and allows five tries. After you verify, we keep a record for you at that store (your email, name, and when you were first and last verified and last seen) and a sign-in session of up to 30 days, stored only as a hash (clause 9.4).
- If you place an order in the chat: the items, quantities and total, the name and email on the resulting invoice, and any note you add. Payment is never taken in the chat; you pay on the normal GetPay invoice page.
- If the store runs a loyalty programme: the stamps or points added when your invoices are paid (matched to your verified email), and any reward the store redeems for you.
- Counts for the store's chat statistics, such as conversations by source, and a short topic label for each question you ask and each catalogue search you make, used for the most-asked topics. A label is the first few words of what you typed, in lower case. We remove email addresses, links, phone numbers and long numbers from it, but it is not anonymised: we cannot reliably spot a name, an address or other details, so a label can contain personal data you wrote at the start of a message. Please keep personal details out of the opening words of a message.
- Like the rest of https://getpay.cc, these pages load the analytics and error-monitoring tools described in clause 9.2.
Why we use it
- To answer you from the store's catalogue, FAQs and promotions, and to hand you to the store's WhatsApp if you ask for a person.
- To check that you are the owner of an email address before showing you anything about orders, and to show only your own orders, pay links, delivery status and loyalty balance.
- To email you a sign-in code, an update on an order, or an invoice or receipt that you ask for. These go only to your verified address. We do not send marketing email or SMS from the storekeeper.
- To pass an order to the store for approval and to alert the store's owners that someone needs them. The alert email names the store and links to its Visitor inbox; it does not contain your messages, email or name.
- To limit abuse, for example by capping how many codes and messages one conversation, one email address or one store can use in a day.
Who sees it
- The store: its owners and admins, and team members the store has given access to the Visitor inbox. They can read the conversation, reply, take over from the AI, approve or decline your order, redeem your loyalty reward and delete your verified profile. Owners and admins can see your full verified email; other team members see it masked. Anyone who can open the store's Visitor inbox analytics also sees the topic labels, in its "Top questions" list.
- Our AI provider, DeepSeek (clause 5.1), whose servers may be outside Malaysia, processes your messages together with the store information and order details the assistant looks up to answer you. The assistant is never shown the code. It sees your email only in masked form (for example
c***@gmail.com). - Resend (clause 5.1) sends the emails described above.
- We do not sell your data or use it for advertising.
How long we keep it: see clause 7.2. In short, conversations are deleted 180 days after they are sent, codes within a day of expiring, and sign-in sessions soon after they expire; invoices and loyalty records stay with the store's accounts. The topic labels in the chat statistics are kept longer than the conversation, for 400 days.
Your choices
- Use Sign out in the chat to end your sign-in on that device, or clear the site's cookies.
- Ask the store to forget you. It can delete your verified profile, sign-in sessions and loyalty balance, and it closes your conversations with the store: you can start a new chat, but you cannot carry on an old one. Your past messages stay, no longer linked to you, until they are deleted at 180 days; invoices and receipts are financial records and are kept. If an order of yours is still waiting for the store's approval when it forgets you, the store can no longer email you its pay link, so ask the store to settle that order first.
- To see, correct or delete other data about your chat, ask the store first, as it decides how the data is used. You can also write to studio.telebort@gmail.com and we will pass your request to the store and help it respond (clauses 10 and 12.3).
Shopping
Clause 2.11. You can sign in to GetPay as a shopper, with a code we email you or with Google, without opening a business account. This clause explains what happens to your data when you do. For your shopper account, your purchase list, your follows and the update emails we send, we (Telebort) are the data controller. When you follow or wave at a store, that store also receives the details listed below and decides how it uses them.
What is collected
- Your email address, the fact that you confirmed it, and when you signed in. Optionally, a display name you choose.
- Your purchase list. We do not copy anything to build it: when you open it, we look up the invoices and receipts that GetPay stores have issued to the email address you confirmed (open, overdue and paid ones only, never drafts or cancelled ones) and show them to you. Each one opens the store's normal GetPay invoice page. A store never learns which other stores you buy from.
- The stores you follow, when you followed them and where you pressed Follow (an invoice page, a store page or Discover).
- Your waves: which store you waved at or waved back to, how many times and when. A wave carries no message.
- Whether you want update emails, and, if you unsubscribe, a one-way hash of your email address so we do not email you again.
- If you continue in a store's chat as your signed-in self, the store's chat receives your email as if you had verified it there with a code (section 2.10).
Why we use it
- To sign you in and show you your own purchases from every GetPay store, and nobody else's.
- To show you updates from the stores you follow, in GetPay and in an update email. Following a store means you agree to receive that store's updates. Each email has a one-click unsubscribe, and you can turn the emails off in Shopping → Me or unfollow a store at any time.
- To pass your wave to the store's team, and their wave back to you.
- To list stores that chose to appear in Discover.
- To limit abuse, for example by capping how many stores you can follow or wave at in a day.
Who sees it
- A store you follow sees your display name (if you set one) and your email address: its owners and admins in full, other team members masked. Everyone can see how many followers a store has, but not who they are.
- A store you wave at sees the same details for the wave. Stores never see your purchase list, the other stores you follow, or your waves to other stores.
- Resend (clause 5.1) sends sign-in codes and update emails.
- We do not sell your data or use it for advertising.
How long we keep it: see clause 7.2.
Your choices
- Unfollow a store, turn update emails off, or use the unsubscribe link in any update email.
- Delete my shopping profile (Shopping → Me) removes your follows, waves, email preference and display name, and signs you out of every store chat you continued in. Your sign-in stays so you can still see your purchases. Invoices and receipts are the stores' financial records and stay with them; a store that received your email when you followed, waved or chatted keeps its own record until you ask it to delete it.
- Signing out of GetPay as a shopper also signs you out of the store chats you continued in as your signed-in self.
3. Sources of Personal Data
3.1 Directly from you — when you register, configure your account, upload data, or contact support.
3.2 From your use of the Service — automatically collected usage data, device data, and cookies.
3.3 From third-party integrations you connect — e.g., bank transaction imports, MyInvois portal, payment gateway providers.
3.4 From third parties — identity verification providers, fraud-prevention services, business directories (where lawful).
3.5 From public sources, for seller invitations — before we invite a seller we may look at public shop pages (on a shopping platform or your own website) and public web search results to find the business and its public shop links. We tell you in the invitation email where we found your business, and we contact only sellers who told us they would like a listing.
4. Purposes and Legal Basis for Processing
We process personal data for the following purposes, with the indicated legal basis under the PDPA:
| Purpose | Legal basis (PDPA) |
|---|---|
| Provide, operate, and improve the Service | Contract performance; legitimate interest |
| Authenticate users and secure accounts | Contract performance; legitimate interest |
| Process payments and billing | Contract performance; legal obligation |
| Comply with tax, accounting, anti-money-laundering, and other legal obligations | Legal obligation |
| Communicate with you (transactional emails, support, service announcements) | Contract performance; legitimate interest |
| Send marketing communications | Consent (you may opt out at any time) |
| Verify directory ownership claims, and publish the contact details supplied on an approved listing | Consent |
| Invite sellers who told us they would like a listing, keep the record of that consent, and publish and maintain a seller listing the seller has approved | Consent |
| Keep a one-way hashed opt-out entry so a seller who declines or unsubscribes is not invited again | Legitimate interest (honouring your opt-out) |
| Let an AI app or agent you connect act on your requests, and keep the record of that connection (clause 5.5) | Contract performance |
| Run a store's storekeeper chat for it: answer customers, verify an email address, show a customer their own orders, send documents they ask for, and run the store's loyalty programme (section 2.10) | The store's instructions, as the controller (clause 12.3); the customer's consent when they enter their email |
| Show a shopper their own purchases from every GetPay store, their follows and updates, and pass waves (section 2.11) | Contract performance (your shopper account) |
| Send update emails from the stores you follow | Consent (given by following; withdraw by unfollowing or unsubscribing) |
| Give a store your email when you follow or wave at it, or continue in its chat as your signed-in self | Consent |
| Detect, prevent, and respond to fraud, security incidents, and abuse | Legitimate interest; legal obligation |
| Develop and improve features, including AI/machine-learning models trained on aggregated or de-identified data | Legitimate interest (with safeguards) |
| Defend or assert legal claims | Legitimate interest; legal obligation |
5. How We Share Personal Data
We do not sell personal data. We may share personal data with the following categories of recipients:
5.1 Service Providers (Sub-processors)
We engage trusted third-party service providers to operate the Service. Current sub-processors include:
| Sub-processor | Purpose | Location |
|---|---|---|
| Supabase | Database, authentication, file storage | United States / Singapore |
| Vercel | Application hosting, edge compute | United States / global |
| DeepSeek | AI copilot, categorisation and storekeeper chat | Provider's servers, which may be outside Malaysia |
| Alibaba Cloud Model Studio (DashScope, Singapore endpoint) | Reading uploaded documents and images (for example receipts, bank statements and directory-claim documents) | Singapore |
| Stripe | Payment processing for subscriptions and AI top-up packs | United States / Singapore |
| Resend | Transactional email, including storekeeper and shopper sign-in codes, and update emails from the stores you follow | Provider's servers, which may be outside Malaysia |
| PostHog | Product analytics, including page views, clicks and session replay | United States |
| Sentry | Error monitoring | Provider's servers, which may be outside Malaysia |
A current list is available on request to studio.telebort@gmail.com. Each sub-processor handles personal data under the terms it has agreed with us.
5.2 Authorities and Law Enforcement
We may disclose personal data when required by law, subpoena, court order, or to protect legal rights, prevent fraud, or comply with anti-money-laundering / tax-reporting obligations (including LHDN submissions where you direct us to submit e-Invoices on your behalf).
5.3 Business Transfers
If we are involved in a merger, acquisition, restructuring, or sale of assets, personal data may be transferred as part of that transaction, subject to confidentiality.
5.4 With Your Consent
We may share personal data for purposes not listed above only with your consent.
5.5 Connected AI Apps and Agents
You can connect an AI app or agent to GetPay: for example ChatGPT, Claude, another app that uses the Model Context Protocol (MCP), or the GetPay command line (CLI). When you connect one, you sign in to GetPay and choose the one company it may act on, and it can only do what your role in that company allows. An MCP app such as ChatGPT or Claude is offered only a fixed set of actions (for example looking up and preparing invoices, customers, products, bills and quotations, and categorising bank transactions); it cannot reach payroll or employee records.
(a) Data goes to the provider you chose. When you, or someone using the connection, ask the app for something, the GetPay data needed to answer (for example invoice details, the names and contact details of your customers and suppliers, amounts, bank transaction descriptions and report figures) is sent to that app and its provider (for example OpenAI for ChatGPT, or Anthropic for Claude). The provider handles that data under your own agreement with it, not under ours. It is not our sub-processor (clause 5.1), and we do not control how it processes, stores or uses that data. Please read the provider's own terms and privacy policy, and connect only apps you are allowed to share your company's data with. With the CLI, the data goes to your own computer and to any AI agent you run there.
(b) Approval for money, legal and outbound actions. Through ChatGPT, Claude or another MCP app, actions such as issuing, voiding or emailing an invoice, recording a payment, or anything else that involves money, a legal document or a message to someone outside GetPay are not carried out until an owner or admin of the company approves them in GetPay. A request from a connected AI app waits up to 24 hours for approval and then expires. A connected AI app can never approve its own request. With the CLI, these actions need your explicit confirmation, or approval in GetPay.
(c) What we keep. We keep a record of each connection: the app's name and identifier, the company, the user who connected it, the permissions granted, and when it was connected, last used and disconnected. Actions that an owner or admin approves are recorded in the company's activity log under the person who approved them. Other changes the app makes directly, such as a draft, are recorded in the company's activity log in the same way as changes made by a person. An action waiting for approval is stored with the details needed to show it to the approver and to carry it out, and with who asked for it, until it is finished or expires. We receive only the requests the app sends to GetPay, not your conversation with the app, and we do not log the content of the answers we send back. Retention is set out in clause 7.2.
(d) Disconnecting. You can disconnect an app at any time in GetPay under Settings → Connected apps, and an owner or admin can disconnect any connection to their company. Disconnecting stops the app from reaching GetPay at once. It does not delete data the provider has already received; ask the provider about that.
6. International Data Transfers
6.1 Your personal data may be transferred to and processed in countries outside Malaysia where our sub-processors operate, including the United States and Singapore. The location of each sub-processor is shown in clause 5.1; where it says "provider's servers", the data may be processed outside Malaysia.
6.2 We transfer personal data outside Malaysia only as needed to provide the Service through the sub-processors listed in clause 5.1, and each of them handles it under the terms it has agreed with us. Transfers of personal data outside Malaysia are subject to Section 129 of the PDPA.
7. Data Retention
7.1 We retain personal data only as long as necessary to fulfil the purposes set out in this Policy, comply with legal obligations, resolve disputes, and enforce agreements.
7.2 General retention guidelines:
| Data category | Retention period |
|---|---|
| Account and identity data | Duration of subscription + 7 years (to meet Malaysian tax-record retention under Section 82 of the Income Tax Act 1967) |
| Directory-claim identity-verification documents (MyKad and/or SSM registration certificate uploaded to verify ownership of a business or practitioner listing in our public directory) | 30 days after the claim is approved, 7 days after it is rejected, or 24 hours after it expires unresolved — at which point the uploaded document and any identity data extracted from it (including the NRIC/IC number) become eligible for permanent deletion. Deletion is carried out by a daily automated process and completes within 24 hours of that eligibility |
| Directory-claim records (your name, the SSM number you stated, your role, the contact details you supplied, and the decision on the claim) | Until you ask us to delete them |
| Seller invitation records (the invited email address, the consent evidence, the invitation status, and any unclaimed draft listing prepared for it) | The draft listing and invitation are deleted when the invitation expires (30 days after it is sent) or is declined, and a draft that was never sent is deleted 30 days after we prepared it; the stored email address is removed as soon as you claim the listing. Deletion is carried out by a daily automated process |
| Seller opt-out entry (a one-way keyed code made from the email address or domain; it cannot be read back or confirmed without our secret key) | Kept for as long as we send seller invitations, so that your opt-out is honoured |
| Seller listing data (the listing fields, any private SSM number, contact details supplied, and your consent record for the listing) | Until you delete the listing, or we remove it |
| Seller application log entry (your workspace identifier, the unique identifier of the user who applied, and the time of the application; used only to limit applications, not to identify you to the public) | Deleted at most 90 days after the application. A daily automated clean-up deletes every entry older than 90 days |
| Connected-app records (the app's name and identifier, the company, the user who connected it, the permissions granted, and when it was connected, last used and disconnected) | For as long as the account exists, as the company's connection history. The sign-in tokens issued to the app are deleted by a daily automated process 30 days after they expire |
| Actions from a connected app waiting for approval (the action's details, who asked for it, and the outcome) | Deleted by a daily automated process once the request is finished or has expired and is more than 30 days old |
| Storekeeper conversations and messages (section 2.10) | 180 days after each message is sent, then deleted by a daily automated process. The demo store is wiped every night |
| Storekeeper email codes | Deleted 24 hours after the code expires (a code is valid for 10 minutes) |
| Storekeeper sign-in sessions | Up to 30 days; deleted 7 days after they expire or you sign out |
| Storekeeper chat statistics (counts and the source of a visit) | 400 days |
| Storekeeper topic labels (the opening words of a question or catalogue search, in the chat statistics; a label can contain personal data you typed, see section 2.10) | 400 days, which is longer than the 180 days that apply to the message itself |
| Storekeeper verified-customer profile (email, name, verification dates) | Until the store forgets you, or 24 months with no sign-in session, order, loyalty record or conversation, whichever comes first |
| Storekeeper chat orders and loyalty records | Kept with the invoice they belong to, as part of the store's financial records (see the next row) |
| Shopper profile (display name, email preference) | Until you delete your shopping profile or your account |
| Follows and waves | Until you unfollow / delete your shopping profile; waves with no activity for 12 months are deleted |
| Store updates (text, image, product link) | Until the store deletes them; deleted updates and their images are removed within 30 days |
| Update-email unsubscribe entry (a one-way hash of your email) | For as long as we send update emails, so the opt-out is honoured |
| Customer-uploaded accounting records | Duration of subscription; after termination, exportable for 30 days (clause 7.3), after which it may be deleted, except where the law requires us to keep it (up to 7 years) |
| Billing and payment records | 7 years from the date of the transaction |
| Service usage logs | 13 months (rolling) |
| Communication records | 3 years from the date of the communication |
| Marketing consent records | Until withdrawn + 3 years |
7.3 Upon termination of your account, Customer-uploaded data stays exportable for thirty (30) days, after which we may delete it, except where the law requires us to keep it (up to seven (7) years).
7.4 Directory-claim identity-verification documents (clause 7.2) are retained only for the bounded window tied to that specific claim's outcome, not the general 7-year "Account and identity data" period — a claim you submit to verify a directory listing is evidence-of-check, not a tax or accounting record. An approved claim carries a short fraud/dispute window; a rejected claim's documents may belong to someone unrelated to the listing, so we have no ongoing reason to hold them; an expired, unresolved claim granted nothing at all. This clause governs those documents even where you are otherwise an authenticated account holder of the Service.
8. Security
8.1 We implement reasonable technical and organisational measures to protect personal data, including:
- Encryption in transit (TLS) and at rest (where applicable)
- Access controls and authentication (including multi-factor authentication options)
- Regular security testing and code review
- Segregation of duties and least-privilege access for our team
- Logging and monitoring of administrative actions
- Incident response procedures
8.2 No system is perfectly secure. In the event of a personal data breach likely to cause harm, we will notify affected data subjects and the Personal Data Protection Commissioner as required under applicable law.
8.3 You are responsible for protecting your account credentials and notifying us promptly of any unauthorized access.
9. Cookies and Similar Technologies
9.1 We use cookies and similar technologies for the following purposes:
| Category | Purpose | Consent required? |
|---|---|---|
| Strictly necessary | Session management, security, load balancing, and the storekeeper chat cookies in clause 9.4 | No |
| Functional | Remembering preferences (language, theme, and whether you last used GetPay for your business or for shopping — the gp_mode cookie) | Implied consent |
| Analytics and error monitoring | Product analytics (PostHog) and error reports (Sentry) | Not currently asked — see clause 9.2 |
| Marketing | None currently | N/A |
9.2 PostHog (product analytics, including automatic capture of page views and clicks, and session replay where it is turned on in our PostHog project) and Sentry (error monitoring) start when you first visit https://getpay.cc. We do not currently show a cookie-consent banner. You can block these tools, and delete the cookies and similar storage they use, through your browser settings.
9.3 You may manage cookie preferences via your browser settings. Disabling strictly necessary cookies will impair the Service.
9.4 The storekeeper chat (section 2.10) sets these cookies. They are strictly necessary for the chat to work, are not used for advertising or tracking across sites, and cannot be read by page scripts (they are "HttpOnly"). They are set only when you send a message or verify your email.
| Cookie | Purpose | Lifetime |
|---|---|---|
gp_chat_<store> | Remembers your conversation with that store | 7 days |
gp_ck_<store> | Keeps you signed in after you verify your email | Up to 30 days, or until you sign out |
gp_chat_e_<store> and gp_ck_e_<store> | The same two cookies when the chat is on a store's own website. getpay.cc sets them inside the chat frame as "partitioned" third-party cookies, so each one works only on the site where you set it and is not shared with other sites | 7 days and up to 30 days |
The <store> part is the store's GetPay handle, as in getpay.cc/c/<store>.
10. Your Rights Under the PDPA
If you are a data subject whose personal data we process, you have the following rights under the Personal Data Protection Act 2010:
- Right of Access (Section 30) — Request access to your personal data and a description of the processing.
- Right of Correction (Section 34) — Request correction of inaccurate, incomplete, misleading, or outdated data.
- Right to Withdraw Consent (Section 38) — Withdraw consent at any time. We will cease processing within a reasonable period.
- Right to Prevent Processing Likely to Cause Damage or Distress (Section 42) — Require us to cease processing for purposes likely to cause substantial damage or distress.
- Right to Prevent Processing for Direct Marketing (Section 43) — Require us to cease processing for direct marketing.
Submitting Requests
To exercise these rights, contact studio.telebort@gmail.com. We will respond within twenty-one (21) days of receipt of a complete request, as required by Section 31 of the PDPA. A prescribed fee may apply for access requests.
Right to Lodge a Complaint
If you are dissatisfied with our handling of your personal data, you may lodge a complaint with the Personal Data Protection Commissioner Malaysia at https://www.pdp.gov.my.
11. Children's Data
The Service is not directed to individuals under the age of eighteen (18). We do not knowingly collect personal data from children. If we learn that we have collected personal data from a child, we will delete it promptly.
12. Customer Data Subjects (Data Processing on Your Behalf)
12.1 Where you (the Customer) upload personal data about third parties (your customers, suppliers, employees) into the Service, you are the data controller for that data and we act as your data processor.
12.2 Our processing on your behalf is governed by our standard Data Processing Agreement (available on request). In summary, we will:
- Process Customer Data only on your documented instructions
- Implement appropriate security measures
- Engage sub-processors subject to equivalent data protection obligations
- Assist you in responding to data subject requests
- Notify you of personal data breaches without undue delay
- Return or delete Customer Data on termination
12.3 Store customers. When someone chats with a store's storekeeper (section 2.10), the store is the data controller for the conversation, the customer's verified profile, their orders and their loyalty records, and we process that data on the store's behalf under clause 12.2. The store decides what to put in its FAQs, promotions and loyalty programme, whether the chat may take orders, and who on its team can read the Visitor inbox. We act as a controller only for the limits and logs we keep to protect the Service from abuse and to keep it secure. If you contact us about your data from a store's chat, we will pass your request to the store and help it respond. Follower and wave details a store receives under clause 2.11 are the store's own records once received; the store is their controller.
13. Changes to This Policy
13.1 We may update this Policy from time to time. The "Last updated" date at the top reflects the most recent revision.
13.2 For material changes, we will provide notice via email or in-Service notification at least thirty (30) days before the effective date. Continued use of the Service after the effective date constitutes acceptance.
14. Contact
For privacy questions, requests, or complaints:
TELEBORT AI STUDIO PLT (LLP0046066-LGN; SSM Reg. No. 202604000838) Data Protection Contact: studio.telebort@gmail.com Address: 1, Jalan Kaki Bukit, Kampung Kastam, 11700 Gelugor, Pulau Pinang, Malaysia
Version log
- v1.0 — 2026-05-11 — First version.
- v1.1 — 2026-05-13 — Added a statement about our AI sub-processor.
- v1.2 — 2026-07-25 — Added retention periods for directory-claim identity documents.
- v1.3 — 2026-07-25 — Clarified that those documents are deleted by a daily process within 24 hours of the retention period ending.
- v1.4 — 2026-10-01 — Corrected the sub-processor list (DeepSeek, Alibaba Cloud Model Studio, Stripe, Resend, PostHog, Sentry) and international transfers; described analytics as it runs today; added directory claims and public listings; named Stripe and self-billing; aligned data after termination with the Terms; updated the registered address.
- v1.5 — 2026-10-04 — Added seller listings and invitations (clause 2.9), with matching scope, purpose and retention entries.
- v1.6 — 2026-10-05 — Added connected AI apps and agents (clause 5.5): data goes to the provider you choose under your own agreement with it, approvals in GetPay, what we keep, and disconnecting; with matching purpose and retention entries.
- v1.7 — 2026-10-08 — Added the storekeeper chat (clause 2.10): what is collected, why, who sees it and your choices; the storekeeper sign-in cookies (clause 9.4); retention entries; the store-customer processor role (clause 12.3); the AI-provider and email rows in clause 5.1; and that the topic label in the chat statistics is the opening words of a message and can contain personal data, with its own 400-day retention entry.
- v1.8 — 2026-10-10 — Added shopping on GetPay (clause 2.11): the purchase list across stores, following, waves, store updates and update emails, continuing in a store's chat as a signed-in shopper; with matching scope, purpose, sub-processor, retention, cookie and store-customer entries.