Privacy Notice (For Customers)

(If you are reading this Privacy Notice on behalf of a body corporate/business enterprise which maintains/maintained contractual relationship with TNGD Group, this Privacy Notice is intended to be addressed to, without limitation, the individual officers (e.g. authorised signatories/dealer and company secretary), directors, shareholders, beneficial owners (e.g. sole proprietor and partners), guarantor or obligor of the body corporate/business enterprise (the “Relevant Individuals”) and “you” shall be construed accordingly to mean the Relevant Individuals).

At TNGD Group, we value your privacy and strive to protect your personal information in compliance with the laws of Malaysia.

Pursuant thereto, this Privacy Notice is designed to explain and elaborate upon some of our policies and principles pertaining to the privacy of your personal information, all of which we have adopted as a sign of our commitment to respecting, maintaining, protecting and safeguarding the privacy of your personal information.

TNGD Group will process your personal information in accordance with the Malaysian Personal Data Protection Act 2010 (the “PDPA”) and other applicable data protection or privacy laws and regulations, and in compliance with this Privacy Notice and any other applicable terms and conditions governing data protection and privacy as may be agreed by you via any other agreement(s) with a TNGD Group entity.

Processing refers to any operation or set of operations performed on personal data, including technical or administrative activities such as collecting, recording, holding, storing, organizing, adapting, altering, retrieving, consulting, using, disclosing (via transmission, transfer, dissemination, or making available), aligning, combining, correcting, erasing, and/or destroying personal data.

Where necessary, TNGD Group reserves the right to update, rectify, and/or amend your personal data to ensure accuracy, completeness, and compliance with applicable legal and regulatory requirements. Any such update, rectification, and/or amendment will be carried out in accordance with the PDPA and other applicable data protection or privacy laws and regulations, subject always to your provision of valid supporting documents.

This Privacy Notice explains:

The type of personal information we collect and how we collect it;
How we use your personal information;
The parties that we disclose the personal information to; and
The choices we offer, including how to access and update your personal information.

Your privacy matters to us, so please take the time to get to know our practices and if you need further information, please contact our TNG Digital Careline.

For the purposes of this Privacy Notice, please note that:

“TNGD Group” or "We" refers to TNG Digital Sdn Bhd* (Registration No: 201701042478) (1256651-M) and all its associates as well as subsidiaries or related companies, including but not limited to TNG Digital Group Sdn Bhd, and jointly controlled companies, excluding companies, branches, offices and other forms of presence operating outside of Malaysia unless and to the extent otherwise stated.
“TNG Group” refers to Touch ‘n Go Sdn Bhd** and all its associates as well as subsidiaries or related companies, including but not limited to CIMB Group Holdings Berhad***, and jointly controlled companies, providing financial and other regulated services, excluding companies, branches, offices and other forms of presence operating outside of Malaysia unless and to the extent otherwise stated.
“Personal information” refers to any information which relates directly or indirectly to you and/or your transactions with us. This includes both non-sensitive personal data and sensitive personal data, as defined under the PDPA.
- Non-Sensitive Personal Data includes, but is not limited to, your name, identification number, nationality, address, date of birth, gender, occupation, employer details, contact information (phone number, email address), financial and banking details, transactional records, and other relevant information related to your engagement with our products and services.
- Sensitive Personal Data includes data related to your physical or mental health, religious beliefs, political affiliations, criminal records, biometric data, or any other information that may be classified as sensitive under the PDPA. We will only process such data in accordance with applicable legal requirements, including obtaining your explicit consent where necessary.
This Privacy Notice applies solely to individuals and governs how we collect, use, disclose, and safeguard your personal data in accordance with the PDPA.

Our Commitment

We will safeguard, according to strict standards of security and confidentiality, any information our customers share with us.
We will limit the collection and use of customer information to the minimum as may be required to deliver superior service to our customers, which includes advising our customers about our products, services and other opportunities, and to administer our business.
We will permit only authorised employees, who are trained in the proper handling of customer information, to have access to that information.
Whenever we hire other organisations to provide support services, we will require them to conform to our privacy standards.
To make sure your personal information is secure, we communicate our privacy and security guidelines to TNGD employees and strictly enforce privacy safeguards within the company.

What Kind Of Personal Information We Collect And How We Collect It

If you are below the age of eighteen (18), you are responsible to obtain consent from your parent, guardian or person who has parental responsibility, prior to disclosing your personal details to TNGD Group. TNGD Group shall not be liable for any loss or inconvenience to you for failing to obtain consent.

In order to enable us to perform our services, offer our products to you, deal with your inquiries, open and operate an account for you and/or to fulfil partly or all of the services requested by you, we may need to and/or be required to process personal information and data about you, including but not limited to:

personal information typically collected on application forms, which include but not limited to, your name, address details, date of birth, telephone number, mobile phone number, email addresses, bank account information (including but not limited to bank name, bank account number, and account holder name), payment card details, information of work permit, student visa, or professional visa (where necessary and applicable only to non-Malaysian);
personal information such as your profile picture, photos or avatar, gender, age, ethnicity, marital status, educational level, occupation, salary range, interests, hobbies, precise location-based information, device ID or serial numbers, and passwords when you create an account for our services, and any other information you directly give us through TNGD Group portal or any other platforms that may be introduced by TNGD Group;
personal information that pertains to you obtained indirectly through other sources (if any), in respect of which you have given your consent to them disclosing information relating to you and/or where they are not otherwise restricted
personal information including your particulars, images and biometrics to establish your identity and background;
specimen signatures as well as digital or electronic signatures as defined under the applicable laws and regulations;
personal information that you provide when you apply for any of our products and services, including your views or opinions made known to us via feedback or surveys;
information about your risk profile, financial standing and/or business interests and assets;
information which we may collect from written communication when you provide us complaints or issue of inconveniences while using our service and we may use it for the purposes of communicating with you and to efficiently manage your requests and to resolve any other issues you may face;
information such as occupation, language, postcode, area code, unique device identifier, location and the time zone where the TNGD Group products or services are used;
information regarding customer activities on our websites and from our other products and services, which are aggregated and used to help us provide more useful information to our customers and to understand which parts of our websites, products and services are of most interest;
information relating to your activities, habits, preferences and interests arising from your use of products and services of TNGD Group, our partners or vendors; and/or
other electronic data or information relating to you such as IP addresses, cookies, activity logs, online identifiers and location data through your usage of our products and services or as part of their supply or delivery to you.

We may obtain this information from yourself and from a variety of sources, including but not limited to:

through your relationship with us, for example information provided by you in application forms (physical or online through TNGD Group Portal), when you register and operate your account and use our products or services, when taking part in customer surveys, competitions and promotions, when providing feedback or making complaints;
through your verbal and written communications with us and/or our authorised agents via SMS, phone or mobile device, email, fax, mail, websites or browsers, social media and/or any other appropriate communication channels;
from an analysis of the way you use and manage your account(s) with us, from the transactions you make and from the payments which are made to/from your account(s) and use of our products or services;
from recordings of Closed-Circuit Television (CCTV) installed at our premises or wherever our Radio Frequency Identification (RFID) or License Plate Recognition (LPR) products or services are offered;
from the Malaysia Department of Insolvency, other relevant governmental authorities and/or law enforcement agencies to ascertain inter alia your current and past financial standing;
from payment network or other sources (for example from credit reporting/ referencing agencies, including but not limited to Central Credit Reference Information System (CCRIS), Financial Information Services (FIS) and/or any other bureaus or agencies established or to be established by Bank Negara Malaysia or any of its subsidiaries, or by any other authorities and/or from any financial institution);
information received from refund, settlement or reconciliation claims or other documents; and/or
from any information that is supplied and/or collected when you visit our websites and/or download our mobile device applications which may include your device's IP address or from data that is collected via cookies.

We collect both mandatory and optional personal data depending on the service, where mandatory information is required to fulfill your request while optional data is used to enhance your experience.

We use cookies (or equivalent technologies) for a number of purposes, including to store your preference for certain types of information or products, further analysis for the purpose of providing products and services to you, to improve our products and/or to personalize our services to you. Cookies are small text files that collect information about users and their visit to the web site or use of the app, such as their Internet protocol (IP) address, how they arrived at the web site (for example, through a search engine or a link from another web site) and how they navigate within the web site or mobile application.

TNGD Group may use third parties to track its advertising across the web. The information TNGD Group or these third parties collect does not include any personal information but is merely for the purpose of identifying the general effectiveness of such online advertising.

You may adjust settings on your browser and/or mobile device so that you will be notified when you receive a cookie or other similar tracking tools. Please refer to your browser documentation to check if the tracking tools have been enabled on your computer and/or mobile device or to request not to receive cookies or to disable cookies if you do not wish to have information collected via the use of cookies. However, do note that if you enable blocking or disabling of cookies, it may limit certain features and functions in your use of our web or mobile sites and that some personalized services on our websites may not be available if you choose to disable cookies.

Third-Party Sites and Services

Our websites, products, applications and services may contain links to third-party websites, products and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details are governed by their privacy practices. This means, third party internet sites that you can link through our websites are not covered by our policy. Therefore, we encourage you to familiarise with those third parties’ sites’ privacy policies before using the links or applications and we urge you to be careful when you enter any personal information online. TNGD Group accepts no responsibility or liability for those sites.

How We Use Your Personal Information

Other than as stated above, we may use your personal information for one or more of the following purposes:

to assess, address or fulfil your registration, orders usage, request(s), application(s), feedback or complaints for our products and services;
to provide you with a better personalized experience on our websites;
to process refunds;
to conduct credit checks (including but not limited to ensure our business partners are of sound financial standing);
to manage and maintain your account(s) with us;
to better manage our business and your relationship with us;
to understand your current and future products, services and advertising needs;
to market and to provide you with information on TNGD Group, TNG Group and selected third parties products, services, offers and/or contests which may be of interest to you (in respect of which we may or may not be remunerated) including but not limited to e-money or cashless payment and related services and products, and services and products offered by our co-branding partners (the names of such partners will be provided during the application of the relevant services and products, as the case may be) and in this respect, to contact you via short message service (“SMS”), phone or mobile device, email, fax, mail, websites or browsers, social media or messaging, in person and/or any other appropriate communication channels;
to improve our products and services and to test, research, analyse and develop new products/ new features of products and/or services;
to notify you about benefits and changes to the features of products and services;
to administer offers, competitions and promotions;
to provide customer service, assess your interest in TNGD Group’s products and services, market research purposes and to conduct customer research or satisfaction surveys;
to provide you with products and services provided or administered by our agents, affiliates, service providers, contractors (including sub-contractors), merchant and business partners as part of the services and benefits granted by us;
to respond to your enquiries and complaints and to generally resolve disputes;
to protect our rights or property of TNGD Group, or the rights of others including our business partners, suppliers, clients, or others when we have reasonable grounds to believe that such rights or property have been or could be affected, or to comply with a judicial proceeding, court order, or legal process;
to update, consolidate and improve the accuracy of our records;
to produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
to conduct research for analytical purposes including but not limited to information processing, management and enhancement of data, data mining and analysis of your transactions with us;
to meet the disclosure requirements of any law binding on TNGD Group;
to create and maintain risk related models relating to audit, compliance and risk management purposes or functions;
to analyse your credit and repayment behaviour scoring as part of our compliance monitoring purposes;
to assess financial risks;
to transfer or assign our rights, interests and obligations under any of your agreements with us;
to protect or enforce our rights to recover any debt owing to us;
to conduct anti-money laundering checks;
for crime detection, investigation, prevention and prosecution;
to comply with any sanction or law enforcement requirements;
to enforce and/or defend any of our rights; and/or
for any other purpose that is required or permitted by any law, regulations, guidelines and/or the order of any court and/or relevant regulatory authorities.

When providing personal or financial information for services available on TNG eWallet on behalf of third parties (such as spouses, next-of-kin, or emergency contacts), you represent and warrant that you have obtained their prior consent or are otherwise authorized to share their data in accordance with this Privacy Notice. You are responsible for ensuring the accuracy of this information, providing timely written updates of any significant changes, and ensuring these individuals are made aware of this Privacy Notice. Please be aware that if a third party withdraws their consent, we may be required to terminate your account or related services.

Please be assured that we will ask for your consent before using your personal information for a purpose other than those that are set out in this Privacy Notice and in the privacy terms in your agreement(s) with TNGD Group.

How We Use Technology to Serve You

We use automated technology to enhance, improve and/or optimize our services over time, helping us provide personalized support, verify your identity securely, and protect your account from fraud.

Disclosure Of Your Personal Information

In providing you with our products and services and the management and/or operation of the same and/or for any of the purposes as set out in this Privacy Notice in relation to our use of your personal information, you consent and authorise us to disclose information about you and/or your accounts with us to (whether in or outside Malaysia):

all the entities within the TNGD Group (whether in or outside Malaysia);
all the entities within the TNG Group;
companies and/or persons that act as our agents, affiliates, service providers, contractors, merchants, business partners, lawyers, and/or professional advisers (including the employees, directors, sub-contractors, service providers, agents and professional advisors of all the aforesaid companies and/or persons);
companies, banks, payment network, financial institutions and/or organisations that assist us in processing and/or otherwise fulfilling transactions that you have requested;
companies and/or organisations that assist us in providing value added services;
companies and/or organisations that provide services to us in delivering or communicating information about our products and services to you;
any authority, central depository or depository agent in relation to the securities industry;
any insolvency department and our appointed debt recovery agents;
any other person under a duty of confidentiality to us which has undertaken to keep such information confidential;
any trustees, beneficiaries, administrators or executors;
your advisers (including but not limited to accountants, auditors, lawyers, financial advisers or other professional advisers) where authorised by you;
any other person notified by you as authorised to give instructions or to use the account(s) or products or services on your behalf;
any party we may deem necessary to facilitate any investigation related to fraud and/or illegal activities;
any law enforcement, government, courts, dispute resolution bodies and regulatory bodies including Bank Negara Malaysia and their appointed personnel or party; and/or
any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us, subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to the TNGD Group (whether in or outside Malaysia). The afore-mentioned third parties may in some instances be located outside of Malaysia.

Marketing

The information you provide to TNGD Group, as well as information we collected about you indirectly, may be used by TNGD Group for marketing purposes. TNGD Group may extract, disclose and release the information in the possession of TNGD Group relating to you as mentioned in this Privacy Notice.

Additionally, the individual entities within the TNGD Group, may contact you about products, services and offers, which we believe may be of interest to you or benefit you financially.

Further, please also be informed that we will only disclose your personal information (which will not include information relating to your affairs or accounts) to third parties such as our merchants and strategic partners for marketing and promotional purposes where your express prior consent has been obtained and subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to the TNGD Group.

You may inform us at any time if you do not wish to receive direct marketing communications from us by notifying us via the Chatbot provided at the end of this Privacy Notice or by using the opt-out function on the ‘Edit Info’ page in the TNG eWallet. Your latest written instructions to us will prevail.

We will treat your personal information as private and confidential and will not disclose your information to anyone outside the TNGD Group except:

where you have given your express consent as set out in our application form(s) and/ or pursuant to your consent and authorisation as contained in this Privacy Notice and/or in the terms and conditions governing the products and services which you have with us and/or under any of your agreements with us;
where we are required or permitted to do so by law;
where required or authorised by any order of court, tribunal or authority, whether governmental or quasi-governmental with jurisdiction over TNGD Group;
where we may transfer rights and obligations pursuant to our agreement(s) with you; and/or
where we are required to meet our obligations to any relevant regulatory authority (whether in or outside Malaysia).

Security Of Your Personal Information

Information is our asset and therefore TNGD Group places great importance on ensuring the security of your personal information in accordance with the PDPA. TNGD Group takes precautions including administrative, technical and physical measures to safeguard your personal information against loss, theft and misuse, as well as against unauthorised access, disclosure, alteration and destruction.

Furthermore, we intend to protect your personal information and to maintain its accuracy. TNGD Group implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. We regularly review and implement up-to-date technical and organisational security measures when processing your personal information.

Employees of TNGD Group are trained to handle the personal information securely and with utmost respect, failing which they may be subject to disciplinary action.

‍Retention Of Your Personal Information

TNGD Group will retain your personal information in compliance with this Privacy Notice and/or the terms and conditions of your agreement(s) with TNGD Group for the duration of your relationship with us or for as long as your account is active or as needed to provide you with our services and products, or as necessary to perform our obligations to you or to enforce or defend the interests of TNGD Group and/or its customers as may be deemed necessary, including for a period as necessary following the termination of your relationship or account closure or as required by applicable law and TNGD Group’s policies in relation to data retention.

What If Personal Information Provided By You Is Incomplete?

Where indicated (for example in application forms or account registration), it is obligatory to provide your personal information to us to enable us to process your application for our products or services. Should you decline to provide such obligatory personal information, we may not be able to process your application or registration, your requests and complaints or provide you with our products or services. You shall update us on any changes to your personal information recorded with us to keep your personal information accurate, complete and up to date.

Your Rights To Access And Correct Your Personal Information

We can assist you to access and correct your personal information held by us.

Where you wish to have access to your personal information in TNGD Group’s possession, or where you are of the opinion that such personal information held by us is inaccurate, incomplete, misleading or not up-to-date, you may make a request to us:

email to ask@naditech.io

We will use reasonable efforts to comply with your request to access or correct your personal information within 21 days of receiving your request and the relevant processing fee (if any).

Please note that TNGD Group may have to withhold access to your personal information in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event we receive repeated requests for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.

Please also note that TNGD Group may use its discretion in allowing the corrections requested and/or may require further documentary evidence of the new information to avoid fraud and inaccuracy.

Please ensure your personal information (such as your mailing address(es), email address(es) and telephone number(s) recorded with us are current, complete and accurate. Please notify us of any change in your personal particulars via the channels made available by us to ensure that all correspondence and/or communication reach you in a timely manner and to enable us to serve you better.

If you wish to request that we no longer use your personal data or limit the usage of your personal data in anyway whatsoever, you may contact TNGD Group. However, please note that TNGD Group may not be able to proceed with the provision of the relevant product or services and you may not be able to use such product and services thereafter.

The personal data requested by TNGD Group are mandatory for the relevant product or services which you must provide and agree to the processing of such personal data. Should you decide not to provide any or all of the personal data, TNGD Group may not be able to proceed with the provision of the relevant product or services and you may not be able to use such product and services thereafter.

‍Exercising Choices Over The Disclosure, Retention and Use of Your Personal Information

Subject always to our contractual rights and obligations under relevant laws and regulations, you may exercise your choice in respect of the disclosure, retention and use of your personal information. Should you wish to do so, kindly contact us at the Careline or Chatbot given at the end of this Privacy Notice.

Please take note that certain communications such as emails, newsletters, statements of account and/or our websites contain standard information regarding our other products and services that cannot be removed without affecting the delivery/provision of our services and/or products, the operation of your account(s) with us, and/or additional costs to you.

Revisions To Privacy Notice

This Privacy Notice may be revised from time to time. Notice of any such revision will be given on TNGD Group’s website and/or by such other means of communication deemed suitable by TNGD Group.

Contacting TNGD Group About Your Privacy And How We Handle Your Personal Information

Should you have any query in relation to this Privacy Notice or how we handle your personal information, kindly contact us at the following contact points:

Email	ask@naditech.io
Address	Level 5, Tower 6, Avenue 5, The Horizon, No. 8, Jalan Kerinchi, Bangsar South, 59200 Kuala Lumpur

* TNG Digital Sdn Bhd is a wholly-owned subsidiary of TNG Digital Group Sdn Bhd.

** Touch ‘n Go Sdn Bhd is an associate company to TNG Digital Sdn Bhd.

*** Touch ‘n Go Sdn Bhd is a wholly-owned subsidiary of CIMB Group Holdings Berhad.

In the event of any conflict or inconsistency between the English and Bahasa Malaysia versions of this Privacy Notice, the English version shall prevail to the extent of such conflict or inconsistency.

Last Updated: 13 August 2026