Privacy Policy of trackerhero.com

Summary

Owner and Data Controller

Type of Data we collect

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:

• Trackers
• Usage Data
• answers to questions
• clicks
• keypress events
• motion sensor events
• mouse movements
• scroll position
• touch events
• email address
• full name
• NRIC / MyKad number or other national identification number
• passport number (for non-Malaysian personnel)
• photograph
• phone number
• employer, job title, staff or guard identification number
• geolocation data (when using our mobile applications)
• device identifiers
• attendance, patrol, incident and shift records
• payroll and statutory contribution data (MesraHR only: EPF, SOCSO, EIS, PCB numbers)
• biometric data, where a customer enables biometric verification

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Identification numbers (NRIC / MyKad / passport)

Some of our products require a national identification number — in Malaysia, the NRIC (MyKad) number; for foreign personnel, a passport or work permit number. We want to be explicit about how this is handled.

Why we collect it. An identification number is collected only where it is necessary for one or more of the following:

• to verify that a person deployed to a site is the person the client contracted for, and to prevent identity substitution at guard posts;
• to uniquely identify an individual across attendance, patrol, payroll and leave records, where names alone are not reliable;
• to prepare statutory submissions and reports required by Malaysian law or by our clients’ regulators (for example EPF/KWSP, SOCSO/PERKESO, LHDN, or KDN-licensed security operations);
• to produce site attendance, deployment or audit reports contractually required by a client;
• to detect, investigate and prevent fraud, duplicate records or unauthorised access.

How we handle it. Identification numbers are treated as confidential. We apply access controls so that only authorised personnel and authorised users of the relevant client account can view them; we mask the number in interfaces and exports wherever full display is not necessary; we do not use identification numbers for marketing, profiling or advertising; and we do not sell, rent or trade them.

Where it comes from. An identification number may be provided by you directly when you create or complete an account, or it may be entered into our platform by your employer or by a client organisation that has engaged us. In the latter case, that organisation is the data controller and we act as its data processor — see Personal Data processed on behalf of our customers.

If you would rather not provide it. Where an identification number is mandatory for a particular function, we will not be able to provide that function without it. Where it is optional, this will be indicated at the point of collection. If you are unsure, contact our Data Protection Officer at [email protected].

Sensitive Personal Data

Certain categories are treated as Sensitive Personal Data under the PDPA — including information about physical or mental health, religious beliefs, the commission or alleged commission of an offence, and (following the Personal Data Protection (Amendment) Act 2024) biometric data such as fingerprint or facial recognition templates. We process Sensitive Personal Data only where a customer specifically enables a feature that requires it (for example biometric clock-in, or medical leave records in MesraHR), and only with the explicit consent required by law or where otherwise permitted under the PDPA.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Personal Data processed on behalf of our customers

Most of the identity data described above does not reach us because an individual gave it to our website. It reaches us because an organisation — a security company, an employer, a property manager — subscribed to one of our platforms and entered records about its own personnel, residents or tenants.

In that situation:

• The customer organisation is the data controller. It decides what personal data to enter, why, and for how long. It is responsible for issuing a PDPA notice to the individuals concerned and for obtaining their consent.
• We are the data processor. We process that data only on the customer’s documented instructions and in order to provide the platform. We do not use it for our own purposes, we do not sell it, and we do not use it to train models or build products unrelated to the service we were engaged to provide.
• Security obligations apply to us directly. Since the Personal Data Protection (Amendment) Act 2024, data processors are directly bound by the Security Principle under the PDPA. We maintain access controls, encryption in transit, logging, and vendor controls accordingly.
• Requests are routed to the controller. If you are an employee, guard, resident or tenant and you want to access, correct or delete your records, please contact the organisation that enrolled you. If you contact us directly, we will forward your request to that organisation and tell you that we have done so, unless the law requires otherwise.
• Deletion on termination. On termination of a customer’s subscription, we return or delete the personal data held for that customer in accordance with the applicable service agreement, subject to any retention required by law.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:

• Traffic optimization and distribution
• Spam and bots protection
• Contacting the User
• Displaying content from external platforms
• Registration and authentication of account holders
• Identity verification of personnel, including verification against an NRIC / MyKad or passport number
• Provision of workforce, attendance, patrol, payroll and property management functions
• Statutory, regulatory and client reporting
• Billing, invoicing and payment processing
• Customer support and service administration
• Security monitoring, audit, and fraud and abuse prevention

Detailed information on the processing of Personal Data

Contacting the User

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Spam and bots protection

This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.

Traffic optimization and distribution

This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Cookie Policy

This Application uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users in Malaysia (PDPA)

This section applies to all Users in Malaysia and to all personal data processed by Ultrack Technology Sdn. Bhd. in Malaysia, under the Personal Data Protection Act 2010 (Act 709) as amended by the Personal Data Protection (Amendment) Act 2024, together with the regulations, orders, standards, circulars and guidelines issued under it (collectively, the “PDPA”). For such Users, this section supersedes any other divergent or conflicting statement contained in this privacy policy.

By providing your personal data to us, or by continuing to access this website or our applications, you confirm that you have read and understood this policy and consent to us processing your personal data in the manner set out in it.

Notice and choice

The PDPA requires us to inform you of the personal data we hold about you, the purposes for which it is or is to be processed, your right to request access to and correction of it, and the class of third parties to whom it may be disclosed. This policy is that notice. It is issued in English; a Bahasa Malaysia version is available on request. In the event of any conflict between the English and Bahasa Malaysia versions, the English version prevails.

Purposes for which we process your personal data

In addition to the purposes described elsewhere in this policy, we may process your personal data:

• to communicate with you and to maintain the customer relationship;
• to assess, process and provide products, services and facilities to you;
• to establish and verify your identity and background, including by reference to your NRIC / MyKad or passport number;
• to administer and process payments, invoices and subscriptions;
• to respond to enquiries and complaints and to resolve disputes;
• to maintain internal records and for internal administration and audit;
• to monitor, review and improve our products and services;
• to detect, investigate and prevent fraudulent, prohibited or illegal activity;
• to enforce our rights and perform our obligations under any agreement with you;
• to meet applicable legal and regulatory requirements and to make disclosures required under any law, regulation, court order, guideline or code applicable to us;
• for direct marketing, where you have consented to receive it.

Where processing for a purpose is optional, you may decline it without affecting the services you have contracted for. You may withdraw consent to direct marketing at any time.

Disclosure of your personal data

We do not sell, rent or trade your personal data. We may disclose it, for one or more of the purposes above, to:

• companies within the Ultrack Technology Sdn. Bhd. group, in Malaysia or overseas;
• the client or employer organisation that enrolled you into one of our platforms;
• our service providers, data processors, hosting and data centre providers, telecommunications providers and IT contractors, engaged under confidentiality obligations;
• payment channels, financial institutions and merchants, in connection with payments due to us;
• our auditors, lawyers, accountants and professional advisers, on a strictly confidential basis;
• government agencies, law enforcement agencies, courts, tribunals, regulators and statutory bodies, where required or authorised to do so;
• any party in relation to legal proceedings or prospective legal proceedings;
• a third party in connection with any actual or proposed merger, acquisition, reorganisation, funding exercise, asset sale or winding-up affecting us.

Your rights under the PDPA

• Right of access. You may request access to, and a copy of, the personal data we hold about you. We may charge a prescribed fee to cover the administrative cost of processing an access request.
• Right of correction. You may request that inaccurate, incomplete, misleading or out-of-date personal data be corrected or updated.
• Right to limit processing. You may at any time ask us to limit the processing of your personal data, including asking us to stop sending you marketing or promotional material.
• Right to withdraw consent. You may withdraw your consent, in whole or in part, by notice in writing. Withdrawal may mean we can no longer provide certain services to you, and may require the termination of your contract with us.
• Right to data portability. Since 1 June 2025, you may request that your personal data be transmitted directly to another data controller, subject to technical feasibility and compatibility of the data format.
• Right to lodge a complaint. You may complain to the Personal Data Protection Commissioner (Jabatan Perlindungan Data Peribadi, Putrajaya) if you believe your rights under the PDPA have been infringed.

We may refuse a request for access or correction in the limited circumstances permitted under the PDPA — for example where the burden or expense of providing access is disproportionate to the risk to your privacy, or where complying would reveal personal data about another individual. Where we refuse, we will tell you why.

To exercise any of these rights, write to our Data Protection Officer at [email protected]. Where the personal data concerned was uploaded by an employer or client, see Personal Data processed on behalf of our customers — we will route your request to them.

If you do not provide your personal data

The provision of personal data may be mandatory or voluntary depending on the purpose. Where it is mandatory — for example an NRIC / MyKad number required for identity verification or statutory reporting — and you do not provide it, or you do not consent to this policy, we may be unable to provide the relevant products, services or facilities, or to continue dealing with you.

Accuracy of your personal data

We rely on you to provide accurate information. As a condition of us providing products and services to you, you warrant that the personal data you submit is accurate, complete, not misleading and up to date, and you undertake to notify us promptly when it changes.

Retention

We retain personal data for as long as the purpose for which it was collected continues, after which it is destroyed or permanently deleted in accordance with our retention schedule — unless a longer retention period is required to meet our operational, legal, regulatory, tax or accounting obligations, or the obligations of the client on whose behalf we hold it.

Security and data breach notification

We implement technical, physical, electronic and procedural safeguards appropriate to the risk, and we require our staff, contractors, vendors and data processors to keep your personal data confidential. No transmission over the Internet is completely secure, and email is not secure unless encrypted.

In line with Section 12B of the PDPA and the Commissioner’s Data Breach Notification guidelines, if we have reason to believe a personal data breach has occurred we will notify the Personal Data Protection Commissioner as soon as practicable and, where required, within 72 hours of becoming aware of it. Where the breach is likely to cause significant harm, we will also notify affected individuals without unnecessary delay. Where we act as a data processor, we will notify the relevant customer organisation so that it can meet its own notification obligations.

Transfer of your personal data outside Malaysia

Our storage facilities, servers and service providers may be located outside Malaysia — including, as described in this policy, in the United States. Your personal data may therefore be transferred to, stored in or accessed from a jurisdiction that may not offer a level of protection equivalent to that provided under Malaysian law. Consistent with the Commissioner’s Cross-Border Personal Data Transfer guidelines, we transfer personal data outside Malaysia only where the receiving jurisdiction provides comparable protection or where adequate contractual and technical safeguards are in place, and we take reasonable steps to ensure recipients use the data only for the permitted purposes. By using our services you consent to such transfers.

Personal data about minors and other individuals

If you provide us with personal data about another person — a family member, a dependent, an emergency contact, or an employee — you confirm that you have informed them that their data will be provided to and processed by us, and that you have obtained their consent. In the case of minors (individuals under 18) or individuals not legally competent to give consent, you confirm that you are authorised to consent on their behalf.

Data Protection Officer

Further Information for Users in the European Union

This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes.
• Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• Processing is necessary for compliance with a legal obligation to which the Owner is subject;
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology – e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

PDPA

The Malaysian Personal Data Protection Act 2010 (Act 709), as amended by the Personal Data Protection (Amendment) Act 2024, together with the regulations, orders, standards, circulars and guidelines made under it.

Sensitive Personal Data

Personal data consisting of information as to physical or mental health or condition, political opinions, religious beliefs or other beliefs of a similar nature, the commission or alleged commission of any offence, biometric data, or any other personal data determined by the Minister under the PDPA.

NRIC / MyKad number

The identification number assigned to a Malaysian citizen or permanent resident on the national identity card (MyKad). Referred to in Malaysia in everyday use as the “IC number”. For non-Malaysians, the equivalent identifier is a passport or work permit number.

Data Controller (PDPA)

The person who, alone or jointly with others, controls the processing of personal data. This term replaced “data user” under the Personal Data Protection (Amendment) Act 2024, and corresponds to the Data Controller (or Owner) described above.

Legal information

This policy relates solely to this Application, if not stated otherwise within this document.

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