1. Halo Telco Top Up and Validity


• 1.1 Halo Telco Prepaid subscribers are required to purchase airtime credit via Top-Up Vouchers to ensure their Account is active in order to use the Services. As a subscriber you may top up your service subscription via Halo Telco Self Care Mobile Application (“App”) or by purchasing valid Halo Telco top up vouchers from any Halo Telco authorised dealers or sale outlets.
• 1.2 The validity period of your Account is determined by the value of the credit you buy via the Top-Up Voucher as displayed on the voucher, App and/or listed on www.halogo.my. Halo Telco reserves the right to change or modify the denominations or validity period without prior notification.
• 1.3 Upon successful purchase of top up, you will be notified via text message of the top up amount, total available credit and new validity period. Halo Telco is not responsible for, nor do we refund lost, stolen, misused, or damaged top up vouchers or PINs.
• 1.4 All top up purchases are final and non-refundable, regardless of who actually uses or possesses the vouchers or PINs, with or without your consent.
• 1.5 You are only allowed to have a maximum airtime credit of Ringgit Malaysia One Thousand (RM1,000/-) only (“Maximum Airtime Credit Limit”) at any one time during your subscription to Halo Telco Service and upon reaching the Maximum Airtime Credit Limit. Any attempt to top up will be disallowed.
• 1.6 Halo Telco provides various payment methods for you to perform the reload transaction in the Platform, which includes but not be limited to:
  • a. Credit card;
  • b. Debit card;
  • c. FPX; and
  • d. e-Wallet applications.
• 1.7 Halo Telco reserves the right at its own discretion to add or discontinue any payment methods stated in Clause 1.6 above. You will have the option to save your payment method for the subsequent transactions in the Platform.
• 1.8 In addition, Halo Telco is not liable for any loss or damage due to top up errors or mistake caused by the user of the voucher.
• 1.9 Top-Up Vouchers which have passed the expiry date imprinted on them will not be usable and/or returnable.
• 1.10 Halo Telco is not liable for refunding or compensating expired top up voucher PINs. All top up or reload purchase including online top up are final and not refundable.
• 1.11 Halo Telco shall not be liable for any loss sustained by subscriber for any unsuccessful top up transaction done through any online or offline platforms caused by any technical disruptions. All queries pertaining to the above Top up should be directed to Halo Telco’s Customer Care by calling 011-50505020 or 03-5870 3107 from 8am to 9pm daily.
• 1.12 Ensure you reload before the Top-Up validity expires or you will only be able to receive incoming calls and SMS for a grace period of 45 days. During the grace period, you are unable to perform any outgoing calls, outgoing SMS, and any other Services that we may determine until you top up your account. After the grace period ends, service will then be terminated. Unused credit and Tune Talk points will be forfeited and the mobile number cannot be reactivated.


2. Transaction History and Statement


• 2.1 You may view your monthly statement and/or transaction history up until ninety (90) days in your account at any time. If you intend to view your transaction history after ninety (90) days, you shall contact our customer service for assistance. You should regularly review your monthly statement and transaction history to ensure that there have not been any unauthorized transactions. In the event that you discovered any unauthorized transactions in your account, kindly contact our customer service for assistance.


3. Fees, Charges, Payment Terms, Interest and Taxes


• 3.1 All payments under these Terms and Conditions shall be made payable in Ringgit Malaysia (RM) only.
• 3.2 Unless otherwise stated, all prices, fees, charges, interests and/or Taxes are accurate at the time of entering the information onto the Platform. The total cost of your purchase is the price of the Product and/or Service which may or may not be inclusive of any applicable Taxes, fees and/or interests.
• 3.3 Unless otherwise stated, all payments made are strictly not refundable nor exchangeable in any kind.
• 3.4 Despite our best efforts, occasionally the Platform may experience system errors (“Errors”) which includes but not limited to:
  • a. incorrectly priced Products and/or Services;
  • b. incorrect deductions of amount of purchase and/or transactions;
  • c. miscalculation of any payment, charges, fees, interest, taxes or prices; and
  • d. miscalculation of errors in any rewards and amount of rewards or incentives credited in your account.
• 3.5 In the event that any of these Errors occur, Halo Telco has the sole discretion to determine, amend, vary, revoke and/or revise the Errors. Halo Telco reserves the right to request from you, within a reasonable time, to reimburse to Halo Telco any amount of monies which was incorrectly paid by Halo Telco to you due to the Error. If the transaction was conducted in the form of Credit in your account, Halo Telco has the right to deduct your Credit balance to remedy the Error upon a written notice on such deduction. In the event that the Credit balance in your account is insufficient for the deduction, Halo Telco shall deduct the credit from your account in the corresponding month’s Credit balance, or reject any use or withdrawal of your Credit in the corresponding months until the total amount of Credit due has been reimbursed.
• 3.6 Halo Telco does not withhold income taxes payable to the Governing Bodies and is not liable to any compensation or obligation with your income taxes (if any). You shall bear the sole responsibility in declaring and paying your obligation for income taxes including all credit earnings, prizes and benefits-in-kind received from Halo Telco.


4. Sale & Purchase of Product


• 4.1 You agree that the Products and Services made available and sold in the Platform may have an expiry date. In the event that the Products are not utilized and/or consumed upon expiration, you shall fully indemnify Halo Telco for the losses caused as a result (if any) and acknowledge that it is strictly a no exchange and no refund sale policy.
• 4.2 In the event that Halo Telco conducts a recall and/or compensation exercise, Halo Telco endeavor to publish a notice for the exercise and all returns must be completed within the stipulated time in the published notice.
• 4.3 You agree to be accountable for any risks of the Products and/or Services, if any, from the time of successful purchase transaction of the Products and/or Services. Upon successful transaction, you shall check and verify that the Products and/or Services are accurate and complete as per what you have purchased. Notwithstanding Clauses 5.4 and 5.5 above, in the event that you notice any issues or have any complaints about the transaction, which includes but not be limited to issues on the amount deducted or charged for the purchase or issues with regards to the Products and/or Services received, you shall contact our customer service for assistance within twenty-four (24) hours from the date of the transaction. In the event that you notice any issues or have any complaints about the Products and/or Services received, you are required to notify Halo Telco of any issues or complaints in writing accompanied by proofs of the Product and/or Services within twenty-four (24) hours from the date of the receipt of the Products and/or Services, failing which no further claims can be made nor will be entertained by Halo Telco. Once the twenty-four (24) hours period has lapsed, you shall be deemed to have accepted the Products and/or Services and Halo Telco shall not in any way be accountable or responsible for any issues. For avoidance of doubt, the issues and/or complaints mentioned in this clause shall include any issues during or after the purchase transaction regarding the system and/or the Products and Services purchased.
• 4.4 Halo Telco shall have the discretion and right to make the relevant checks or calls to any party at any time for verification purposes for any purchases made in the Platform. In the event Halo Telco is unable to perform the verification (without fault on Halo Telco's side) or the verification is unsuccessful in establishing the relevant party's identity, Halo Telco reserves the right to cancel and/or withhold the delivery of the Product.
• 4.5 We may ask for additional personal data, if necessary, for the purposes of verification of your identity or fraud prevention purposes.
• 4.6 In the event that you are found to be conducting any fraudulent activities with regards to the sale and purchase of the Products and/or Services or the use of the Platform, Halo Telco reserves the right to proceed with any further actions against you, including but not limited to imposing a fee or penalty, suspension or termination of your use of the Platform, and/or take any legal actions against you, of which actions shall not be prejudicial to any parties’ rights.


5. Referral, Marketing and Rewards (Where Applicable)


• 5.1 Halo Telco conducts a referral program where you shall be entitled to get rewards if you share your referral codes to prospective Users. Halo Telco provides a referral link sharing service to ease referral of Products and Services to prospective Users. Upon sharing of the referral code and successful registration of the prospective User, the rewards shall be granted to you in your account within the stipulated time.
• 5.2 Halo Telco also conducts marketing and rewards program for the Users from time to time which shall entitle the Users to obtain rewards if they fulfil the requirements of the specific program. The marketing and rewards program shall include but not be limited to rewards for lucky draws, contests, promotions and campaigns. The details and requirements of the programs shall be governed by the terms and conditions of such program.
• 5.3 Should the reward is granted in the form of Go Life Credits or Coins, the reward amount will be granted to the User’s account. User must ensure that their account is active during the time of granting of Credits or Coins to avoid failure of transaction. Should the reward is in physical form, the User can arrange for self-collection at Halo Telco. For delivery of rewards, delivery charges may be applied to the User.


6. Shipping, Cancellation and Return & Refund


• 6.1 For local orders, we will ship via J&T Express Malaysia. For international orders, we will ship via
• 6.2 The shipping fee will be quoted based on the address and packaging size / weight (weight or volumetric, whichever greater). Orders received will be shipped out from our warehouse within 1 to 3 working days. Orders placed on Friday after 12pm and over the weekend, will be processed on the following Monday.
• 6.3 Cancellation can be done before shipment is being arranged by our fulfilment department, except for special ordered / custom made items. Cancellation will not be possible once shipment has been arranged.
• 6.4 The returned goods/products will be checked with the receipt together and the goods should be in the good condition. The packaging should also be in original condition in original shipping container as received. If the goods/products has been used or damaged by the customer, there will not be any refund. Halo Telco will also not be responsible if your shipment is lost during the return transit. Once we have checked and confirm the goods/products, customer will received their refund within 14 working days after the confirmation.
• 6.5 Halo Telco reserves the right to amend this policy at any time without prior notice.


7. Amendments


• 7.1 Halo Telco reserves its rights to alter or otherwise vary these Terms and Conditions at any time and shall provide you notice thereof by email or by publishing the change of terms on the Platform or by other reasonable means. It is your responsibility to regularly check the Platform to determine if there have been changes to the Terms and Conditions and to review such changes. Should you be dissatisfied with any terms or conditions, you shall cease the use of the Platform immediately, failing which you shall be deemed to have consented to the Terms and Conditions as modified and/or varied from time to time.
• 7.2 Your continued use of the Platform, Products and/or Services or involvement thereof after notice of any change to the Terms & Conditions shall also be deemed to be your agreement to the amended Terms & Conditions.


8. Acts of Defamation and Violation of Terms


• 8.1 You agree that if you are found to be involved in activities violating the instructions provided by Halo Telco with regards to the use of the Platform, Products and/or Services, including but not limited to suspected fraudulent act in your account registration and/or purchases, does not abide to these Terms and Conditions, does not abide to any other terms & conditions related to the Platform, Products and/or Services, does not abide to the Privacy Notice of Halo Telco, involved in acts of immorality and/or defamation to the Halo Telco brand and/or to any stakeholders of Halo Telco, your account will be indefinitely frozen from access without any form of notice and a related public notice will be published.
• 8.2 Halo Telco reserves the right to proceed with any further actions against you in the event that you are found to be conducting any of the activities mentioned in Clause 9.1 above, including but not limited to imposing a fee or penalty, suspension or termination of your use of the Platform, and/or take any legal actions against you, of which actions shall not be prejudicial to any parties’ rights.
• 8.3 Pursuant to Clause 8.1, all services including but not be limited to reload and purchase transactions, entitlement to incentives, rewards, Credits, promotions, campaigns and withdrawal of Credits will be disabled until your account is proven otherwise. Halo Telco, in its sole discretion, may also suspend your use of other Halo Telco’s websites, mobile applications and/or any other services belonging to Halo Telco which includes but not limited to the following platforms:
  • a. HaloGo Application;
  • b. HaloGo Corporate (where applicable);
  • c. HaloGo Lifestyle; and
  • d. any other Halo Telco's platforms as determined by Halo Telco from time to time.
• 8.4 All Services and entitlement will resume should your account is released.


9. Inheritance and beneficiary


• 9.1 You agree that your account in the Platform is strictly non-transferrable. Every account is linked to the individual’s identification number. Any application for a transfer of ownership of account for any reasons whatsoever will not be entertained.
• 9.2 It is the sole responsibility of the beneficiary of the inherited User’s account to report any incentive earned through the User’s account to the Governing bodies.


10. Information Submitted to Halo Telco


• 10.1 Except for any personal and individually identifying information which we have agreed to keep confidential; any feedback, data, answers, questions, comments, suggestions, plans, ideas or the like that you send to us via the Platform, via email or otherwise, will be treated as being non-confidential and non-proprietary. We assume no obligation to protect such information from disclosure and will be free to reproduce, use, and distribute the information to others without restriction. We will also be free to use any ideas, concepts, know-how or techniques contained in information that you send us for any purpose whatsoever including but not limited to developing, manufacturing and marketing products and services incorporating such information.


11. Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLATFPUAA) & Financial Services Act 2013 (FSA)


• 11.1 Halo Telco and its related companies undertake to adhere and comply to all applicable laws, guidelines, rules, regulations, policies and the like relating to AMLATFPUAA in all activities pursuant to the purposes of this Platform.
• 11.2 Halo Telco undertakes to use, manage and disclose all the documents and/or information collected from you relating to the Services provided in this Platform, in accordance with the Financial Services Act 2013 (FSA).


12. Indemnity


• 12.1 You agree to fully indemnify, defend and hold harmless Halo Telco, its directors, officers, employees, suppliers, licensors, agents, and any third party content providers, from and against any losses, damages, claims, costs, expenses, demands, and actions, due to or arising out of your use of the Platform, your access or connection to the Platform, your violation of these Terms and Conditions, or your violation of any rights of another. Halo Telco reserves the right to assume the defense and control of any matter subject to indemnification by you, in which event you will cooperate with Halo Telco in asserting any available defenses.
• 12.2 Further, you shall indemnify and save harmless Halo Telco against and from all claims, proceedings, damages, costs and expenses which may be brought against Halo Telco or to which he may be subjected to by reason of you infringing or being held to have infringed any intellectual property rights.
• 12.3 Halo Telco shall not be liable in any way to you whether in contract, tort (including negligence or breach of statutory duty) or otherwise for any loss, damage or liability incurred or sustained by you caused by or as a result of:
  • a. any failure, delay, interruption to or disruption of the Platform in the transmission or reception of any data through the Platform, howsoever caused or arising;
  • b. any loss, corruption or deletion of any data or information transmitted to or stored in any system or equipment, howsoever caused or arising;
  • c. a Force Majeure event;
  • d. the disclosure and/or publication by Halo Telco of any information or data relating to you, howsoever caused or arising;
  • e. the use in any manner and/or for any purpose whatsoever by any person at any time whatsoever and from time to time of any information or data relating to you through the use of the Platform; and/or
  • f. any unavoidable error, omission or inaccuracy in any information provided by Halo Telco whether to you or any person and whether in any publication or as part of or in connection with the Platform or otherwise.


13. Governing Law and Jurisdiction


• 13.1 Any agreements created between you and Halo Telco via this Platform will be deemed to have been made in Malaysia only and shall be governed and construed according to the laws of Malaysia. Any disputes or proceedings shall be subject to the exclusive jurisdiction of the Courts of Malaysia.
• 13.2 Halo Telco's failure to insist upon or enforce strict performance of any provision of these Terms shall not be construed as a waiver of any provision or right.
• 13.3 If any part of these Terms and Conditions are held to be unenforceable, the unenforceable part shall be given effect to the greatest extent possible and the remainder will remain in full force and effect.
• 13.4 Any part of these Terms and Conditions that is invalid, unenforceable or illegal shall be enforced as nearly as possible in accordance with its terms, but shall otherwise be deemed severed and shall not affect the enforceability of any other part of the these Terms and Conditions, which shall continue to be valid and enforceable to the fullest extent permitted by law.
• 13.5 These Terms and Conditions are for the benefit of Halo Telco and its directors, officers, employees, suppliers, licensors, agents, and any third party content providers to the Platform. Each of these individuals or entities shall have the right to assert and enforce those provisions directly against you on its own behalf.


14. Severability


• 14.1 If any of these Terms & Conditions in the Platform is held to be illegal or invalid under present or future laws or regulations effective and applicable during the term of this Platform, such Terms & Conditions shall be fully severable and shall be construed as if such illegal or invalid Terms & Conditions had never comprised as part of the Platform and the remaining Terms & Conditions in the Platform shall remain in full force and effect and shall not be affected by the illegal or invalid Terms & Conditions or by its severance from the Platform


15. Your personal information


• 15.1 You should only provide Halo Telco with accurate and complete information where we ask you to provide such information. Please read Halo Telco Privacy Notice for information on why and how we use your personal information, and details on your rights in relation to such information.
• 15.2 The primary responsibility for the observance of the Terms & Conditions and Privacy Notice shall rest with each User. You agree to indemnify and relieve Halo Telco and its related parties including but not limited to its directors, officers, employees, suppliers, licensors, agents, and any third party providers from and against all claims, proceedings, damages, costs and expense which may be brought against them as a result of your breach in any of the Terms & Conditions. Halo Telco and its related parties reserves the right to warn and exercise legal actions for any losses and damage caused by you.
• 15.3 Your use of this website shall also be subject to Halo Telco’s Terms and Conditions, and privacy policy.


16. Contact Us


• 16.1 If you have any questions about these Terms and Conditions, please contact our customer service through the following channels:
  • a. via email at:
    • i. [email protected], or
    • ii. [email protected];
  • b. via our live chat at https://www.halogo.my; or
  • c. or via our customer service hotline at 03-58703107.

BY ACCESSING OR USING THIS PLATFORM YOU AGREE THAT YOU HAVE READ THESE TERMS AND CONDITIONS AND AGREE TO ALL OF THE PROVISIONS CONTAINED ABOVE.

Privacy Policies

• Introduction of our Privacy Notice


• This is a Privacy Notice ("Notice") of Winner Venture Sdn Bhd (Company No. 1285421-A) with its registered address at K-0-8, Kuchai Business Park, Jalan 1/127, off Jalan Kuchai Lama, 58200 Kuala Lumpur (including all of its subsidiaries, brands, related and/or associated companies/brands) for HaloGo's website (the "Platform") users. These entities collectively referred to as "HaloGo", "Halo Telco", "we", "us" or "our". The words "you", "your" and "customer" includes past, current and future customers of the Platform. HaloGo is bound by the Personal Data Protection Act 2010 and all regulations, standards and guidelines as may be prescribed from time to time pursuant to the Personal Data Protection Act 2010. This Notice explains our practices regarding the collection, use, disclosure and transfer of your personal data when you subscribe to and use any of our products and services, including telecommunications network, applications, digital services and solutions, or visit any of our office branches and any of our websites or contact our customer support (collectively referred to as "Services"). Where this Notice is translated into a language other than the English Language, in the event of any inconsistencies, conflicts or discrepancies between the terms set out in the English Language version and that of the other language(s), the English Language version shall prevail.


• On this Platform, we take your privacy seriously. We are committed to complying with all data protection and privacy laws which are applicable to us.
• This Notice is incorporated as part of the Terms of Use of HaloGo Website ("Terms of Use of HaloGo Website"). Your use of the Platform and/or Service is subject to the Terms of Use of HaloGo Website and this Notice. Unless specifically defined in this Notice, the defined terms shall have the same meaning as defined in the Terms of Use of HaloGo Website.
• For the purpose of this Notice, "Personal Data" and "Sensitive Personal Data" shall include the following information:



Personal Data	Any information, whether recorded in a material form or not, from which the identity of an individual and/or entity is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.
Sensitive Personal Data	Comprises information as to the individual's physical or mental health or condition, political opinions, religious beliefs or other beliefs of the same nature, commission or alleged commission of any offence or any other Personal Data determined by law.



• We will only collect, use, disclose and/or process your Personal Data in accordance with this Notice.
• It is important that you read this Notice together with any other applicable notices we may provide on specific occasions when we are collecting, using, disclosing and/or processing Personal Data about you, so that you are fully aware of how and why we are using your Personal Data.
• By clicking or checking "Sign Up", "Log in", "Submit", "I Agree to HaloGo's Privacy Notice" or similar statements available at the Platform's registration page or when you create an account with us, you acknowledge that you have been notified of and understood the terms of this Notice and that you have agreed and consented to the collection, use, disclosure and/or processing of your Personal Data as described and under the terms herein.
• We may revise or update this Notice at any time by posting a revised or an updated version on the Platform. Unless stated otherwise, any revision or update take effects immediately. Any changes we make to this Notice in the future will be posted on the Platform and/or any other means and, where appropriate, notified to you, whereupon your continued use of the Services, access to the Platform or use of the Services, including placing orders on the Platform, shall constitute your acknowledgment and acceptance of the changes we make to this Notice, as notified to you. Please check back frequently to see any updates or changes to this Notice.
• This Notice applies in conjunction with other notices, contractual clauses and consent clauses that apply in relation to the collection, use, disclosure and/or processing of your Personal Data by us, and is not intended to override them unless we state expressly otherwise.
• It is necessary for us to collect and process your Personal Data. If you do not provide us with your Personal Data, or do not consent to this Notice or any amendments to this Notice, we may not be able to render all services to you and you may be required to terminate your relevant agreement with us and/or stop accessing or using the Platform and/or Services.


• The Personal Data We Collect From You


• During the course of your use of the Platform and the provision of the Services, we may collect Personal Data from you, which include but is not limited to:
• Identity data, such as your name, identity number, gender, profile picture, date of birth;
• Contact data, such as billing address, delivery address, email address and phone numbers;
• Account data, such as bank account and payment details;
• Transaction data, such as details about payments to and from you, and other details of products and Services you have purchased from us;
• Technical data, such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Platform;
• Profile data, such as your username and password, purchases or orders made by you, your interests, preferences, feedbacks and survey responses;
• Usage data, such as information on how you use the Platform, products and Services or view any content on the Platform;
• Location data, such as when your device uses Global Positioning System (GPS) data or when your device communicate with cell towers, Wi-Fi routers or access points and/or with other technologies, including the satellites and other location information;
• Biometric data, such as image of your identity document, voice files, and facial images when you upload videos of yourself to the Platform;
• Marketing and communications data, such as your preferences in receiving marketing from us, additional information for winning of contests, and our third parties and your communication preferences; and
• Beneficiary data, such as beneficiary's name, identity number, gender, relationship, mailing address, contact numbers and bank account.
• During the course of your use of the Platform and the provision of the Services, we may receive Personal Data from you in the following situations:
• When you create an account with us;
• When you apply for any of the Services or purchase any products available on the Platform;
• When you use any of the features or functions available on the Platform or Services, including the recording of any user-generated content to be uploaded on the Platform, and registering and managing of the products;
• When you subscribe to our publications or marketing collaterals;
• When you enter a competition, promotion or survey;
• When you participate in any activity or campaign on the Platform;
• When you log in to your account on the Platform or otherwise interact with us via an external service or application, such as Facebook or Google;
• When any other user of the Platform posts any comments on the content you have uploaded on the Platform or when you post any comments on other users' content uploaded to the Platform;
• When a third party lodges a complaint against you or the content you have posted on the Platform; and
• When you access or use mobile games using our Services; and
• When you interact with us online and offline, including when you interact with our in-house or outsourced customer service agents.
• During the course of your use of the Platform and the provision of the Services, we may also receive your Personal Data from third parties for the purposes set out in this Notice or any other terms.
• You must only submit Personal Data which is accurate and not misleading and you must keep it up to date and inform us of any changes to the Personal Data you have provided to us. We shall have the right to request for documentation to verify the Personal Data provided by you as part of our customer verification processes.
• We will only be able to collect your Personal Data if you voluntarily submit the Personal Data to us or as otherwise provided for under this Notice. Unfortunately, if you choose not to submit your Personal Data to us or subsequently withdraw your consent to our use of your Personal Data, we may not be able to provide you with the Services or access to the Platform.
• You may access and update your personal information submitted to us at any time as described in Clause 5 below.
• If you provide the Personal Data of any third party to us, you represent and warrant that you have obtained the necessary consent from that third party to share and transfer his/her Personal Data to us, and for us to collect, use and disclose that data in accordance with this Notice.


• Use and Disclosure of Personal Data


• The Personal Data we collect from you or via third parties may be used by us, or shared with or transferred to third parties (including related companies, third party service providers and their service providers and related companies, third party agents, and companies located both inside and outside your home country), for certain purposes, which include but are not limited to the following:
• To facilitate your use of the Services or access to the Platform, including responding to your queries, feedback, claims or disputes through our in-house and outsourced customer service agents;
• To process orders you have submitted through the Platform;
• Payments that you make through the Platform for our products, whether sold by us or a third party agent that will be processed by our agent;
• To deliver the products you have purchased through the Platform whether sold by us or a third party agent. We may pass your personal information on to a third party in order to make delivery of the product to you (for example to our courier or supplier);
• To update you on the delivery of the products, whether sold through the Platform by us or a third party seller, and for customer support purposes;
• To compare information, and verify with third parties in order to ensure that the information is accurate;
• To administer your account with us;
• To verify and carry out financial transactions in relation to payments you make online;
• To audit the downloading of data from the Platform;
• To improve the layout or content of the pages of the Platform and customise them for users;
• To identify visitors on the Platform;
• To carry out research on our users' demographics and behaviour;
• To audit and conduct necessary actions in relation for the purpose of managing and administering the use of services, products and standard operation procedures on the Platform;
• To provide you with information we think you may find useful or which you have requested from us, including information about our or third party agents' products and services, provided you have indicated that you have not objected to being contacted for these purposes;
• To allow other users to identify you via the "Find Agent" (or similar function) as a user of the Service, to allow you to find other users and to connect with them on the Platform, and to support the socializing function of the Services;
• To promote the Services and use the information that you give to us, such as user-generated content (including video content) that you can choose to broadcast on our Platform, as part of our advertising and marketing campaigns to promote the Platform;
• To process any complaints, feedback, enforcement action and take-down requests in relation to any content you have uploaded to the Platform;
• To display on scoreboards on the Platform in relation to campaigns, mobile games or any other activity;
• To derive further attributes relating to you based on Personal Data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;
• We may also use your personal information to send you marketing or promotional materials about our products and services from time to time, unless you choose to opt-out from receiving these materials; and
• We may also conduct automated-decision making processes in accordance with any of these purposes.
• You may unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies.
• In exceptional circumstances, we may be required to disclose personal information, such as when there are grounds to believe that the disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes, or for fulfilment of legal and regulatory requirements and requests.
• We may share and permit the sharing of your Personal Data with third parties and our affiliates for any of the abovementioned purposes, including but not limited to, facilitating your use of the Services, completing a transaction with you, managing your account and our relationship with you, marketing and fulfilling any legal or regulatory requirements and requests as deemed necessary by us. In sharing your Personal Data with them, we endeavour to ensure that the third parties and our affiliates keep your Personal Data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your Personal Data only for as long as they need your Personal Data to achieve the abovementioned purposes.
• If you are located in Malaysia, we may transfer or permit the transfer of your Personal Data outside of Malaysia for any of the purposes set out in this Notice.
• Withdrawal of Consent to Continued Use, Disclosure and/or Processing of Personal Data
• You may communicate the withdrawal of your consent to the continued use, disclosure and/or processing of your Personal Data including Personal Data relating to others who may be identified from that Personal Data for any of the purposes and in the manner as stated above at any time, by contacting us at [email protected].
• Please note that if you communicate your withdrawal of your consent to our use, disclosure or processing of your Personal Data for the purposes and in the manner as stated above, we may not be in a position to continue to provide the Services to you or perform on any contract we have with you, and we will not be liable in the event that we do not continue to provide the Services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.


• Updating Your Personal Data


• It is important that the Personal Data you provide to us is accurate and complete for you to continue using the Platform and for us to provide the Services. You are responsible for informing us of changes to your Personal Data, or in the event you believe that the Personal Data we have about you is inaccurate, incomplete, misleading or out of date.
• You can update your Personal Data at any time by accessing your account on the Platform. If you are unable to update your Personal Data through your account, you can do so by contacting us at [email protected].
• We take steps to share the updates to your Personal Data with third parties and our affiliates with whom we have shared your Personal Data if your Personal Data is still necessary for the above-stated purposes.


• Accessing Your Personal Data


• If you would like to request information about your Personal Data which we have collected, or enquire about the ways in which your Personal Data may have been used, disclosed or processed by us within the past year, please contact us at [email protected]. In order to facilitate processing of your request, it may be necessary for us to request further information relating to your request.
• We reserve the right to charge a reasonable administrative fee for retrieving your Personal Data records. If so, we will inform you of the fee before processing your request.
• We will respond to your request as soon as reasonably possible. If we are unable to respond to your request within forty-five (45) days from the date of your request, we will inform you in writing. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable data protection laws).


• Security of Your Personal Data


• To safeguard your Personal Data from unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
• Restricting access to Personal Data to individuals who require access;
• Maintaining technology products to prevent unauthorised computer access; and
• Using 128-bit SSL (secure sockets layer) encryption technology when processing your financial details.
• If you believe that your privacy has been breached by HaloGo, please contact us at [email protected].
• You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
• Your password is the key to your account. Please use unique numbers, letters and special characters, and do not share your HaloGo password to anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences. If you lose control of your password, you may lose substantial control over your Personal Data and other data submitted to HaloGo. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us at [email protected] and change your password. You are reminded to log out of your account, clear the history of the application including but not limited to the cache and cookies, and close the application when you are finished with using a shared device.


• Retention of Personal Data


• We will only retain your Personal Data for as long as we are either required to by law or as is relevant for the purposes for which it was collected.
• We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the Personal Data was collected, and is no longer necessary for any legal or business purpose.


• Children and Minors Under 12 Years of Age


• HaloGo does not sell products for purchase by children under 12 years of age, nor does it intend to provide any of the Services or the use of the Platform to children under 12 years of age. We do not knowingly collect any Personal Data relating to children under 12 years of age.
• You hereby confirm and warrant that you are currently 12 years old or above and you are capable of understanding and accepting the terms of this Notice. If you are under 12 years old, you may use our Platform only with the involvement of a parent or guardian.
• As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to HaloGo. In the event that such Personal Data of a minor is disclosed to HaloGo, you hereby consent to the processing of the minor's Personal Data and accept and agree to be bound by this Notice and take responsibility for his or her actions.
• We will not be responsible for any unauthorised use of the Services on the Platform by yourself, users who act on your behalf or any unauthorised users. It is your responsibility to make your own informed decisions about the use of the Services on the Platform and take necessary steps to prevent any misuse of the Services on the Platform.


• Collection of Computer Data


• We or our authorised service providers may use cookies, web beacons, and other similar technologies for storing data to help provide you with a better, faster, safer and personalised experience when you use the Services or access the Platform.
• When you visit the Platform through your computer, mobile device, or any other device with internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website. This data may include:
• Your computer or device's IP address;
• Browser type;
• Webpage you were visiting before you came to the Platform;
• The pages within the Platform which you visit; and
• The time spent on those pages, items and data searched for on the Platform, access times and dates, and other statistics.
• This data is collected for analysis and evaluation in order to help us improve our website and the services and products we provide.
• Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognize a particular device or browser and help us to personalise the content to match your preferred interests more quickly, and to make the Services and the Platform more convenient and useful to you.
• You may be able to manage and delete cookies through your browser or device settings. For more information on how to do so, visit the help material of your browser or device.
• Web beacons are small graphic images that may be included on our Service and the Platform. They allow us to count users who have viewed these pages so that we can better understand your preference and interests.


• Halo Go's Right to Disclose Personal Data


• You acknowledge and agree that HaloGo has the right to disclose your Personal Data to any legal, regulatory, governmental, tax, law enforcement or other authorities or the relevant right owners, if HaloGo has reasonable grounds to believe that disclosure of your Personal Data is necessary for the purpose of meeting any obligations, requirements or arrangements, whether voluntary or mandatory, as a result of cooperating with an order, an investigation and/or a request of any nature by such parties. To the extent permissible by applicable law, you agree not to take any action and/or waive your rights to take any action against HaloGo for the disclosure of your Personal Data in these circumstances.


• Third Party Sites


• The Platform may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.