1. Introduction

This Privacy Policy ("Policy") explains how Vsure Tech Sdn. Bhd., together with its subsidiaries, affiliates, associated companies, and jointly controlled entities (collectively referred to as "VSURE", "we", "our", or "us"), collects, uses, stores, processes, discloses, transfers, and protects your Personal Data in accordance with the Personal Data Protection Act 2010 ("PDPA") and other applicable data protection laws[cite: 5].

This Policy applies to all Personal Data collected through VSURE's digital platforms and services, including but not limited to[cite: 5]:

• VSURE mobile applications ("Apps");[cite: 5]
• VSURE websites ("Websites");[cite: 5]
• Third-party communication platforms, systems, or applications used by VSURE;[cite: 5]
• Products, features, and digital services provided by VSURE; and[cite: 5]
• Any other services operated or made available by VSURE (collectively referred to as the "Services")[cite: 5].

This Policy describes how we process your Personal Data throughout its lifecycle, including the collection, recording, storage, organisation, use, disclosure, transfer, retention, and disposal of such information[cite: 5].

This Policy applies to all individuals and organisations who interact with VSURE, including but not limited to[cite: 5]:

• Customers and prospective customers;[cite: 5]
• Vendors and suppliers;[cite: 5]
• Business, referral, and strategic partners;[cite: 5]
• Contractors and consultants;[cite: 5]
• Service providers; and[cite: 5]
• Any other individual or organisation whose Personal Data is processed by VSURE (collectively referred to as "you" or "your")[cite: 5].

By accessing or using our Services, registering an account, purchasing our products, or otherwise providing your Personal Data to VSURE, you acknowledge that you have read, understood, and agreed to the collection, use, processing, disclosure, and retention of your Personal Data in accordance with this Privacy Policy[cite: 5].

If you do not agree with any part of this Policy, you should discontinue the use of our Services or refrain from providing your Personal Data to VSURE[cite: 5].

2. Definition of Personal Data

For the purposes of this Privacy Policy, "Personal Data" refers to any information relating to an identified or identifiable individual in connection with a commercial transaction, as defined under the Personal Data Protection Act 2010 (PDPA)[cite: 5]. This includes information that can identify an individual either directly or indirectly, whether on its own or when combined with other information in our possession[cite: 5].

Personal Data also includes Sensitive Personal Data and any expression of opinion about an identifiable individual[cite: 5].

2.1 Examples of Personal Data

Depending on the nature of your relationship with VSURE and the Services you use, Personal Data that we may collect and process includes, but is not limited to[cite: 5]:

• Full name;[cite: 5]
• Date of birth and age;[cite: 5]
• National Registration Identity Card (NRIC), passport, or other government-issued identification numbers;[cite: 5]
• Residential, mailing, or billing address;[cite: 5]
• Contact information, including telephone number and email address;[cite: 5]
• Employment and occupation details;[cite: 5]
• Financial and banking information;[cite: 5]
• Vehicle registration details;[cite: 5]
• Information relating to your family members, beneficiaries, or emergency contacts; and[cite: 5]
• Any other personal information that you voluntarily provide or consent for us to collect in accordance with applicable laws[cite: 5].

2.2 Examples of Sensitive Personal Data

Sensitive Personal Data refers to categories of Personal Data that require a higher level of protection under applicable laws[cite: 5]. Subject to your explicit consent or where otherwise permitted by law, VSURE may collect and process Sensitive Personal Data, including but not limited to[cite: 5]:

• Biometric information (such as fingerprints, facial recognition data, or DNA profiles);[cite: 5]
• Information relating to your physical or mental health;[cite: 5]
• Religious beliefs or affiliations;[cite: 5]
• Information relating to the commission or alleged commission of any offence;[cite: 5]
• Personal opinions or assessments relating to you; and[cite: 5]
• Any other information classified as Sensitive Personal Data under the PDPA or other applicable legislation[cite: 5].

VSURE will only collect, use, process, or disclose Sensitive Personal Data where it is necessary for legitimate business purposes, required by law, or with your explicit consent, and will implement appropriate administrative, technical, and organisational safeguards to protect such information[cite: 5].

3. Collection of Personal Data

VSURE collects Personal Data to provide, improve, and administer our Services, comply with legal and regulatory obligations, and deliver a secure and personalised customer experience[cite: 5]. Depending on the nature of your interaction with us, we may collect Personal Data directly from you, automatically through your use of our Services, or from authorised third-party sources[cite: 5].

Where permitted by applicable law, we may combine Personal Data collected from different sources to ensure that the information we maintain is accurate, complete, and up to date[cite: 5].

3.1 Personal Data Provided by You

We collect Personal Data that you voluntarily provide to us when you interact with VSURE or use our Services[cite: 5]. This may include, but is not limited to, when you[cite: 5]:

• Register or create a user account;[cite: 5]
• Complete application forms, registration forms, or user profiles;[cite: 5]
• Apply to become a VSURE referral or business partner;[cite: 5]
• Purchase or subscribe to our products or services;[cite: 5]
• Submit information to determine your eligibility for our products, services, rewards, incentives, or cashback programmes;[cite: 5]
• Participate in surveys, promotional campaigns, contests, or events organised by VSURE;[cite: 5]
• Contact our customer support team or submit enquiries, feedback, or complaints;[cite: 5]
• Interact with us through our websites, mobile applications, or social media platforms;[cite: 5]
• Verify your identity using biometric authentication features, where applicable; or[cite: 5]
• Provide any other information necessary for us to deliver our Services[cite: 5].

3.2 Personal Data Collected Through Your Use of Our Services

When you access or use our Apps, Websites, or Services, certain information may be collected automatically to facilitate the operation, security, and enhancement of our Services[cite: 5]. Such information may include[cite: 5]:

• Location information, including driving routes and driving patterns where relevant;[cite: 5]
• Transaction details, including payment methods and service-related transactions;[cite: 5]
• Device information, such as device model, operating system, IP address, browser type, unique device identifiers, hardware information, and software versions;[cite: 5]
• Usage information, including features accessed, pages viewed, browsing behaviour, and interaction with our Services;[cite: 5]
• Communications submitted through in-app messaging or customer support channels;[cite: 5]
• Customer feedback, ratings, compliments, and reviews; and[cite: 5]
• Vehicle information required for insurance or takaful applications and related services[cite: 5].

3.3 Personal Data Obtained from Third Parties

We may obtain your Personal Data from authorised third parties where such collection is permitted by law and necessary for the provision of our Services[cite: 5]. These sources may include[cite: 5]:

• Referral programmes;[cite: 5]
• Business partners, including insurance, takaful, financing, payment, and technology partners;[cite: 5]
• Government agencies and regulatory authorities;[cite: 5]
• Publicly available sources;[cite: 5]
• Marketing and data service providers;[cite: 5]
• Enterprise customers and corporate partners; and[cite: 5]
• Individuals who nominate you as an emergency contact or authorised representative[cite: 5].

VSURE will take reasonable steps to ensure that any Personal Data obtained from third parties has been collected and disclosed in accordance with applicable data protection laws[cite: 5].

3.4 Personal Data of Referral Partners

If you register as a VSURE referral partner, we may collect additional information necessary to support your participation in our platform, including[cite: 5]:

• Telematics information, such as driving speed, acceleration, braking, and driving behaviour;[cite: 5]
• Device information, including GPS location, accelerometer data, IMEI number, and other technical device identifiers;[cite: 5]
• Vehicle registration information; and[cite: 5]
• Vehicle insurance or takaful policy information[cite: 5].

Such information enables VSURE to assess service quality, facilitate insurance-related services, enhance road safety initiatives, and improve platform performance[cite: 5].

3.5 Image Capture and Identity Verification

Certain VSURE partners may utilise mobile device cameras or other digital verification technologies to capture identification documents, vehicle information, or other supporting documentation required to facilitate insurance, takaful, verification, or related services[cite: 5].

Where such collection is performed by an independent partner, the collection, use, disclosure, and protection of the Personal Data are the responsibility of the respective partner[cite: 5]. Users are encouraged to review the applicable privacy practices of those partners where appropriate[cite: 5].

3.6 Personal Data of Minors

VSURE does not knowingly collect Personal Data from individuals under the age of majority without the consent of a parent or legal guardian[cite: 5].

Parents and legal guardians are responsible for ensuring that minors under their care do not submit Personal Data to VSURE without appropriate authorisation[cite: 5]. Where a parent or legal guardian provides or permits the disclosure of a minor's Personal Data, they consent to the processing of such information in accordance with this Privacy Policy[cite: 5].

3.7 Personal Data of Other Individuals

You may, from time to time, provide Personal Data relating to another individual, such as your spouse, family member, beneficiary, emergency contact, or authorised representative[cite: 5].

By providing such information, you represent and warrant that[cite: 5]:

• You have obtained the necessary consent or legal authority to disclose the Personal Data to VSURE;[cite: 5]
• The individual has been informed of the purposes for which the Personal Data will be processed; and[cite: 5]
• The information provided is accurate and complete to the best of your knowledge[cite: 5].

VSURE reserves the right to request evidence of such consent where required by applicable law[cite: 5].

4. Use of Personal Data

VSURE processes your Personal Data only for lawful purposes and in accordance with the Personal Data Protection Act 2010 (PDPA)[cite: 5]. The Personal Data collected may be used, combined, analysed, and processed to deliver our Services, fulfil contractual and legal obligations, enhance customer experience, and support our business operations[cite: 5].

We will only use your Personal Data for purposes that are consistent with those described in this Privacy Policy or as otherwise permitted or required by applicable laws[cite: 5].

4.1 Provision of Products and Services

Your Personal Data is used to establish, manage, deliver, and improve the products and services offered by VSURE[cite: 5]. This includes[cite: 5]:

• Creating, maintaining, and administering your user account;[cite: 5]
• Verifying your identity and eligibility to access our Services;[cite: 5]
• Processing applications, subscriptions, purchases, and renewals;[cite: 5]
• Facilitating insurance, takaful, financing, and related financial services;[cite: 5]
• Processing payments, refunds, rewards, incentives, and cashback programmes;[cite: 5]
• Validating vehicle information and supporting insurance-related transactions;[cite: 5]
• Personalising your experience across our Apps and Websites;[cite: 5]
• Maintaining service records and customer profiles;[cite: 5]
• Performing system administration, troubleshooting, diagnostics, testing, research, and analytics;[cite: 5]
• Monitoring service usage and improving the functionality, reliability, and performance of our Services; and[cite: 5]
• Supporting communications between users and authorised business partners where necessary[cite: 5].

4.2 Safety, Security, and Fraud Prevention

We process Personal Data to maintain the security, integrity, and reliability of our Services, protect our users, and prevent fraudulent or unlawful activities[cite: 5].

This may include[cite: 5]:

• Verifying your identity during registration and login;[cite: 5]
• Screening referral partners or other authorised users before granting access to our Services;[cite: 5]
• Monitoring driving behaviour, including speeding, harsh braking, acceleration, and other telematics information where applicable;[cite: 5]
• Detecting, preventing, investigating, and responding to fraud, cyber threats, security incidents, and unauthorised access;[cite: 5]
• Monitoring compliance with our Terms of Service, internal policies, and codes of conduct; and[cite: 5]
• Assisting law enforcement agencies or regulatory authorities in the prevention, detection, or investigation of criminal or unlawful activities where required by law[cite: 5].

4.3 Customer Service and Support

Your Personal Data enables us to provide effective customer service and technical support, including to[cite: 5]:

• Respond to enquiries, requests, feedback, and complaints;[cite: 5]
• Investigate and resolve service-related issues;[cite: 5]
• Communicate updates regarding your requests or reported incidents;[cite: 5]
• Monitor and improve the quality of our customer support services; and[cite: 5]
• Maintain records of customer interactions for quality assurance and service improvement purposes[cite: 5].

4.4 Research, Analytics, and Service Improvement

VSURE may use Personal Data to better understand customer needs, improve our Services, and develop new products and solutions[cite: 5].

This includes[cite: 5]:

• Conducting research, analysis, and statistical reporting;[cite: 5]
• Performing product testing and quality assurance;[cite: 5]
• Developing and enhancing new products, services, and digital features;[cite: 5]
• Analysing customer preferences and usage trends;[cite: 5]
• Improving operational efficiency and business processes; and[cite: 5]
• Strengthening cybersecurity and data protection measures[cite: 5].

Where practical and appropriate, Personal Data used for research or analytical purposes may be aggregated, anonymised, or de-identified[cite: 5].

4.5 Legal, Regulatory, and Compliance Purposes

We may process your Personal Data where necessary to comply with applicable laws, regulations, legal obligations, or requests from competent authorities[cite: 5].

This includes[cite: 5]:

• Complying with court orders, legal proceedings, or regulatory requirements;[cite: 5]
• Meeting obligations under applicable insurance, financial services, taxation, and anti-money laundering legislation;[cite: 5]
• Establishing, exercising, or defending legal rights and claims;[cite: 5]
• Enforcing our Terms of Service and contractual agreements;[cite: 5]
• Protecting the rights, property, and legitimate interests of VSURE, our customers, business partners, or third parties; and[cite: 5]
• Supporting corporate transactions such as mergers, acquisitions, restructuring, financing, joint ventures, asset transfers, or business reorganisations[cite: 5].

4.6 Marketing and Promotional Communications

Subject to your consent where required by applicable law, VSURE may use your Personal Data to provide information about our products, services, events, promotions, and those of our authorised business partners[cite: 5].

Such communications may include[cite: 5]:

• Product announcements and service updates;[cite: 5]
• Promotional campaigns and exclusive offers;[cite: 5]
• Newsletters and educational content;[cite: 5]
• Invitations to events, seminars, webinars, or customer engagement activities;[cite: 5]
• Seasonal greetings and appreciation programmes; and[cite: 5]
• Customer satisfaction surveys and market research[cite: 5].

Marketing communications may be delivered through various channels, including[cite: 5]:

• Email;[cite: 5]
• Telephone calls;[cite: 5]
• Short Message Service (SMS);[cite: 5]
• Mobile messaging applications;[cite: 5]
• Push notifications;[cite: 5]
• Postal mail; and[cite: 5]
• Other electronic communication channels permitted by law[cite: 5].

You may withdraw your consent or opt out of receiving marketing communications at any time by[cite: 5]:

• Clicking the "Unsubscribe" link included in our marketing emails;[cite: 5]
• Updating your communication preferences within your VSURE account or mobile application; or[cite: 5]
• Contacting VSURE using the contact details provided in this Privacy Policy[cite: 5].

Your decision to opt out of marketing communications will not affect our ability to send you important administrative, transactional, legal, or service-related communications that are necessary for the provision of our Services[cite: 5].

5. Disclosure of Personal Data

VSURE may disclose your Personal Data to third parties where it is necessary to provide our Services, fulfil contractual obligations, comply with legal or regulatory requirements, or support our legitimate business operations[cite: 5].

We will only disclose your Personal Data on a need-to-know basis and, where appropriate, ensure that recipients are subject to appropriate confidentiality, security, and data protection obligations in accordance with applicable laws[cite: 5].

5.1 Disclosure to Other Users

Where required for the provision of our Services, VSURE may disclose limited Personal Data to other authorised users of the platform[cite: 5].

Examples include[cite: 5]:

• If you are a customer, your location or service-related information may be shared with an authorised referral partner or service provider to facilitate the requested service[cite: 5].
• If you are a referral partner, certain Personal Data such as your name, profile photograph, age, service rating, or other relevant information may be shared with customers to enable the delivery of services and enhance customer confidence[cite: 5].

VSURE will only disclose information that is reasonably necessary for the intended purpose[cite: 5].

5.2 Disclosure to Insurance, Financial, and Other Third Parties

Where you apply for or utilise insurance, takaful, financing, payment, or other related services through VSURE, we may disclose relevant Personal Data to authorised third parties involved in delivering those services[cite: 5].

These may include[cite: 5]:

• Insurance and takaful providers;[cite: 5]
• Reinsurers;[cite: 5]
• Financial institutions;[cite: 5]
• Payment service providers;[cite: 5]
• Claims administrators; and[cite: 5]
• Other service providers necessary to process your transactions or fulfil contractual obligations[cite: 5].

Such disclosures are made only for purposes directly related to the products or services you have requested[cite: 5].

5.3 Disclosure Within the VSURE Group

VSURE may share your Personal Data with its subsidiaries, affiliated companies, associated companies, jointly controlled entities, and other members of the VSURE group of companies[cite: 5].

Such sharing enables us to[cite: 5]:

• Provide integrated products and services;[cite: 5]
• Maintain consistent customer records;[cite: 5]
• Improve operational efficiency;[cite: 5]
• Support customer service functions;[cite: 5]
• Conduct internal reporting and analytics; and[cite: 5]
• Meet legal, regulatory, governance, and compliance requirements[cite: 5].

All entities within the VSURE group are required to protect your Personal Data in accordance with this Privacy Policy and applicable data protection laws[cite: 5].

5.4 Disclosure to Service Providers and Business Partners

VSURE engages trusted third-party service providers and business partners to perform functions on our behalf[cite: 5]. Where necessary, these parties may have access to Personal Data solely for the purpose of performing services for VSURE[cite: 5].

These parties may include[cite: 5]:

• Payment processors and payment gateway providers;[cite: 5]
• Cloud hosting and cloud storage providers;[cite: 5]
• Information technology service providers;[cite: 5]
• Cybersecurity and managed security service providers;[cite: 5]
• Customer support service providers;[cite: 5]
• Marketing agencies and digital marketing platform providers;[cite: 5]
• Data analytics and business intelligence providers;[cite: 5]
• Research organisations conducting surveys or studies on behalf of VSURE;[cite: 5]
• Background screening, identity verification, and anti-money laundering service providers;[cite: 5]
• Referral and agency partners;[cite: 5]
• Insurance, takaful, and financing partners; and[cite: 5]
• Vehicle solution providers, authorised vendors, and related service providers[cite: 5].

VSURE requires these third parties to implement appropriate technical and organisational measures to safeguard Personal Data and prohibits them from using your Personal Data for any purpose other than the services they are contracted to perform[cite: 5].

5.5 Disclosure to Legal Advisors and Government Authorities

VSURE may disclose Personal Data where required or permitted by law to[cite: 5]:

• Courts of competent jurisdiction;[cite: 5]
• Law enforcement agencies;[cite: 5]
• Regulatory authorities;[cite: 5]
• Government bodies;[cite: 5]
• Legal advisors;[cite: 5]
• External auditors; and[cite: 5]
• Other authorised persons or organisations exercising lawful authority[cite: 5].

Such disclosures may occur for purposes including[cite: 5]:

• Compliance with legal or regulatory obligations;[cite: 5]
• Investigation or prevention of fraud or criminal activities;[cite: 5]
• Protection of the rights, safety, and property of VSURE, our customers, employees, or business partners;[cite: 5]
• Enforcement of contractual rights; or[cite: 5]
• Establishment, exercise, or defence of legal claims[cite: 5].

5.6 Safeguards for Disclosure

Whenever VSURE discloses Personal Data to third parties, we will take reasonable steps to ensure that[cite: 5]:

• The disclosure is lawful, necessary, and proportionate;[cite: 5]
• The recipient implements appropriate security measures to protect the Personal Data;[cite: 5]
• Personal Data is processed only for the authorised purposes for which it was disclosed; and[cite: 5]
• Appropriate contractual, technical, and organisational safeguards are in place to protect the confidentiality, integrity, and availability of your Personal Data[cite: 5].

VSURE does not sell or trade your Personal Data to third parties for their independent marketing purposes without your prior consent, except where otherwise permitted or required by applicable law[cite: 5].

6. Retention, Deletion, Disposal and Transfer of Personal Data

VSURE is committed to ensuring that your Personal Data is retained, protected, transferred, and disposed of in accordance with the Personal Data Protection Act 2010 (PDPA), applicable laws, and industry best practices[cite: 5].

6.1 Retention of Personal Data

VSURE will retain your Personal Data only for as long as it is reasonably necessary to fulfil the purposes for which it was collected, including[cite: 5]:

• Providing and administering our products and Services;[cite: 5]
• Maintaining customer and business relationship records;[cite: 5]
• Meeting contractual obligations;[cite: 5]
• Complying with legal, regulatory, taxation, accounting, and audit requirements;[cite: 5]
• Resolving disputes and enforcing contractual rights; and[cite: 5]
• Supporting legitimate business and operational requirements[cite: 5].

The retention period may vary depending on the nature of the Personal Data, applicable legal requirements, and the purpose for which the information was collected[cite: 5].

6.2 Deletion and Disposal of Personal Data

When your Personal Data is no longer required for the purposes described in this Privacy Policy or where retention is no longer required by law, VSURE will take reasonable steps to securely dispose of or permanently delete such information[cite: 5].

Depending on the circumstances, Personal Data may be[cite: 5]:

• Permanently deleted from our systems;[cite: 5]
• Securely destroyed using approved disposal methods;[cite: 5]
• Anonymised or de-identified so that it can no longer be used to identify you; or[cite: 5]
• Archived where required by law or for legitimate business purposes[cite: 5].

VSURE maintains appropriate policies and procedures to ensure that Personal Data is disposed of securely and in a manner that prevents unauthorised access, disclosure, or recovery[cite: 5].

6.3 Protection of Retained Data

Throughout the retention period, VSURE implements appropriate administrative, technical, and organisational safeguards to protect Personal Data against[cite: 5]:

• Unauthorised access;[cite: 5]
• Accidental loss or destruction;[cite: 5]
• Unauthorised disclosure;[cite: 5]
• Alteration or misuse; and[cite: 5]
• Any unlawful processing[cite: 5].

Access to retained Personal Data is restricted to authorised personnel who require such access to perform their job responsibilities[cite: 5].

6.4 Transfer of Personal Data

As part of our business operations, your Personal Data may be transferred, stored, processed, or accessed outside the country, state, or jurisdiction in which it was originally collected[cite: 5].

Such transfers may occur where[cite: 5]:

• VSURE utilises regional or global technology infrastructure;[cite: 5]
• Cloud hosting or data centre services are located in another jurisdiction;[cite: 5]
• Our subsidiaries, affiliates, or business partners operate in different countries;[cite: 5]
• Cross-border support services are required; or[cite: 5]
• International business transactions or operational activities make such transfers necessary[cite: 5].

By using our Services or providing your Personal Data to VSURE, you acknowledge and consent to the transfer, storage, and processing of your Personal Data in jurisdictions outside your country of residence, where permitted by applicable law[cite: 5].

6.5 Cross-Border Data Protection

Where Personal Data is transferred outside your jurisdiction, VSURE will take reasonable measures to ensure that the recipient provides a level of protection that is comparable to the requirements under the Personal Data Protection Act 2010 (PDPA)[cite: 5].

Such measures may include[cite: 5]:

• Entering into appropriate contractual agreements with data recipients;[cite: 5]
• Implementing technical and organisational security controls;[cite: 5]
• Conducting due diligence on service providers and business partners; and[cite: 5]
• Ensuring that cross-border transfers are made only where legally permitted or with your consent where required[cite: 5].

VSURE will continue to take reasonable steps to safeguard your Personal Data regardless of where it is processed or stored[cite: 5].

7. Cookies and Similar Technologies

VSURE and our authorised third-party service providers may use cookies and similar technologies to enhance your experience when accessing our Websites, Apps, and Services[cite: 5]. These technologies help us understand how our Services are used, improve functionality, enhance security, personalise your experience, and deliver relevant content and advertisements[cite: 5].

By continuing to use our Websites or Apps, you consent to our use of cookies and similar technologies in accordance with this Privacy Policy, unless you disable them through your browser or device settings[cite: 5].

7.1 What Are Cookies?

Cookies are small text files or similar technologies that are stored on your computer, mobile device, or browser when you visit our Websites or use our Apps[cite: 5]. Cookies enable websites and applications to recognise your device, remember your preferences, and improve your overall user experience[cite: 5].

In addition to cookies, VSURE may use other tracking technologies, including[cite: 5]:

• Web beacons;[cite: 5]
• Pixel tags;[cite: 5]
• Scripts;[cite: 5]
• Local Shared Objects (such as HTML5 or Flash storage);[cite: 5]
• Advertising identifiers (including mobile advertising identifiers); and[cite: 5]
• Other similar technologies (collectively referred to as "Cookies")[cite: 5].

7.2 Information Collected Through Cookies

Cookies and similar technologies may collect information including, but not limited to[cite: 5]:

• Browser type and version;[cite: 5]
• Device information and operating system;[cite: 5]
• Internet Protocol (IP) address;[cite: 5]
• Device identifiers;[cite: 5]
• Language preferences;[cite: 5]
• Date and time of access;[cite: 5]
• Pages visited and features used;[cite: 5]
• Search and browsing preferences;[cite: 5]
• Referring websites;[cite: 5]
• Advertising interactions; and[cite: 5]
• Other usage and analytical information relating to your interaction with our Services[cite: 5].

Some of this information may constitute Personal Data where it can reasonably identify you[cite: 5].

7.3 Purposes of Using Cookies

VSURE uses Cookies for various legitimate business purposes, including to[cite: 5]:

• Enable the proper operation of our Websites and Apps;[cite: 5]
• Authenticate users and maintain secure login sessions;[cite: 5]
• Remember user preferences and settings;[cite: 5]
• Improve website functionality and user experience;[cite: 5]
• Analyse website traffic and customer behaviour;[cite: 5]
• Monitor system performance and diagnose technical issues;[cite: 5]
• Protect against fraud, abuse, and unauthorised access;[cite: 5]
• Deliver personalised content and recommendations; and[cite: 5]
• Support marketing, advertising, and promotional activities[cite: 5].

7.4 Third-Party Cookies

VSURE may engage trusted third-party service providers, analytics providers, advertising partners, and technology vendors who may place or access Cookies on our Websites and Apps[cite: 5].

These third parties may collect information regarding your interactions with our Services and, where permitted by law, combine such information with data collected from other sources[cite: 5].

VSURE does not control the privacy practices or cookies used by these independent third parties[cite: 5]. Users are encouraged to review the privacy policies of such third parties for further information[cite: 5].

7.5 Advertising and Analytics

Cookies may be used to measure the effectiveness of marketing campaigns, understand customer interests, and display advertisements that may be more relevant to you[cite: 5].

Where permitted by applicable law, VSURE may share non-personally identifiable or aggregated information, including location data, advertising identifiers, or encrypted account identifiers, with authorised advertising and analytics partners to support targeted advertising and performance measurement[cite: 5].

7.6 Managing Your Cookie Preferences

You have the option to manage or disable Cookies at any time through your browser or device settings[cite: 5].

Depending on your browser or operating system, you may be able to[cite: 5]:

• Block all or selected Cookies;[cite: 5]
• Delete existing Cookies;[cite: 5]
• Clear your browser cache and browsing history;[cite: 5]
• Restrict advertising identifiers; or[cite: 5]
• Configure your browser to notify you before Cookies are stored[cite: 5].

Please note that disabling certain Cookies may affect the functionality, availability, or performance of some features of our Websites, Apps, or Services[cite: 5].

VSURE may periodically update its use of Cookies as our technology and Services evolve[cite: 5]. Any significant changes will be reflected in this Privacy Policy[cite: 5].

8. Rights of Data Subjects

VSURE respects your rights under the Personal Data Protection Act 2010 (PDPA) and is committed to ensuring that you are able to exercise your rights in relation to the Personal Data that we collect, use, process, and store[cite: 5].

Subject to applicable laws and any legal or contractual restrictions, you may exercise the following rights[cite: 5].

8.1 Right to Access

You have the right to request access to the Personal Data that VSURE holds about you[cite: 5].

Upon receiving a valid request, and subject to applicable legal requirements, we may provide you with information including[cite: 5]:

• The Personal Data we process about you;[cite: 5]
• The purposes for which your Personal Data is being processed;[cite: 5]
• The categories of Personal Data collected;[cite: 5]
• The recipients or categories of recipients to whom your Personal Data has been disclosed, where applicable; and[cite: 5]
• Any other information required under applicable data protection laws[cite: 5].

VSURE may verify your identity before responding to any access request[cite: 5].

8.2 Right to Correction

You have the right to request the correction, update, or completion of any Personal Data that is inaccurate, incomplete, outdated, or misleading[cite: 5].

VSURE will take reasonable steps to verify the requested changes before updating our records[cite: 5].

8.3 Right to Data Portability

Where permitted under applicable law, you may request that your Personal Data be transmitted to another data controller in a structured, commonly used, and machine-readable format[cite: 5].

Such requests will be processed in accordance with the requirements and limitations prescribed under the PDPA and other applicable legislation[cite: 5].

8.4 Right to Withdraw Consent

Where the processing of your Personal Data is based on your consent, you may withdraw that consent at any time[cite: 5].

You may also choose to opt out of receiving marketing or promotional communications from VSURE by[cite: 5]:

• Clicking the "Unsubscribe" link included in our marketing emails;[cite: 5]
• Updating your communication preferences within your VSURE account or mobile application; or[cite: 5]
• Contacting us using the details provided in this Privacy Policy[cite: 5].

Please note that withdrawing your consent does not affect the lawfulness of any processing carried out before your withdrawal[cite: 5]. In addition, certain Personal Data may continue to be processed where required to comply with legal obligations, fulfil contractual commitments, or protect the legitimate interests of VSURE[cite: 5].

8.5 Exercising Your Rights

If you wish to exercise any of the rights described in this Privacy Policy or have any questions regarding the processing of your Personal Data, you may contact our Data Protection Officer using the contact details provided below[cite: 5].

VSURE may request sufficient information to verify your identity before processing your request in order to protect your Personal Data from unauthorised access or disclosure[cite: 5].

We will respond to your request within a reasonable timeframe and in accordance with the requirements of the Personal Data Protection Act 2010 (PDPA)[cite: 5].

8.6 Contact Details

If you have any questions regarding this Privacy Policy or wish to exercise your rights as a Data Subject, please contact our Data Protection Officer[cite: 5]:

Data Protection Officer (DPO)
Email: info@vsure.life[cite: 5]

VSURE is committed to handling all enquiries, requests, and complaints relating to Personal Data in a fair, transparent, and timely manner[cite: 5].

Amendment to Privacy Policy

VSURE reserves the right to modify, update, or amend the terms of this Privacy Policy at any time by publishing the revised version on the Websites[cite: 5]. Any modifications, updates, or amendments shall take effect upon publication unless otherwise stated[cite: 5].

By continuing to access or use the Apps, Websites, or Services, purchasing products from VSURE, or continuing to communicate or engage with VSURE after such modifications, updates, or amendments have been made, you acknowledge and agree to be bound by the revised terms of this Privacy Policy[cite: 5].

This Privacy Policy is originally prepared in the English language[cite: 5]. In the event of any inconsistency or conflict between the English version and any translated version, the English version shall prevail[cite: 5].