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1.1. Purpose
These documents collectively outline the policies, terms, and conditions (collectively, “Policies”) governing the access to and use of the e-commerce platform Exbit Store, accessible at https://exbit.store (the “Platform”). The Platform is owned and operated by Kompotech Sdn. Bhd. (Company Registration No.:), a company incorporated in Malaysia with its registered address at (hereinafter referred to as “Exbit Store”, “We”, “Us”, or “Our”). These Policies are established to ensure a transparent, fair, and secure environment for all users and to delineate the respective rights and obligations of Exbit Store and its users. Exbit Store is committed to upholding fair business practices and ensuring full compliance with all applicable laws and regulations in Malaysia. A clear legal framework, established from the outset, is fundamental for managing expectations and mitigating risks for an e-commerce platform such as Exbit Store. The explicit identification of Kompotech Sdn. Bhd., along with its registration details, serves to reinforce the legitimacy and transparency of Our operations, aligning with legal requirements for businesses in Malaysia, such as those stipulated in the Consumer Protection (Electronic Trade Transactions) Regulations 2012.1 This foundational clarity is essential for building user trust and ensuring a professional engagement.
1.2. Acceptance of Policies
By accessing, browsing, registering for an account, or otherwise using the Platform, including making purchases or submitting information, you, as a user (“User”, “You”, “Your”), acknowledge that You have read, understood, and agree to be legally bound by these Policies in their entirety. These Policies constitute a legally binding agreement between You and Exbit Store. If You do not agree with any part of these Policies, You must immediately cease all access to and use of the Platform and its Services.
1.3. Applicability
These Policies apply to all individuals and entities who access or use the Platform, including but not limited to registered account holders, casual browsers, buyers of goods (“Goods”), and any other person interacting with the Services offered by Exbit Store. Specific sections of these Policies may apply differently to different categories of Users, as indicated within the relevant sections.
1.4. Governing Law
These Policies, and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims), shall be governed by and construed in accordance with the laws of Malaysia. This choice of governing law is a standard and critical component for e-commerce platforms operating within a specific jurisdiction, ensuring that legal interpretations and dispute resolutions are handled under a consistent and predictable legal framework.2
1.5. Definitions
Unless otherwise defined herein or the context otherwise requires, the following terms shall have the meanings ascribed to them:
These definitions are crucial for ensuring clarity and consistency across all policies, drawing from common practices observed in platforms like Lazada and Shopee.2
2.1. Introduction and Commitment to Privacy
Exbit Store, operated by Kompotech Sdn. Bhd., is deeply committed to protecting the privacy and security of Your Personal Data. This Privacy Policy (“Policy”) explains how We collect, use, disclose, process, and safeguard Your Personal Data when You use Our Platform (https://exbit.store) and Services. We adhere strictly to the requirements of the Malaysian Personal Data Protection Act 2010 (“PDPA”) and its regulations.5 The PDPA governs the processing of personal data in commercial transactions and provides individuals with rights concerning their data.
“Personal Data” as used in this Policy refers to any information that can be used to identify an individual, either on its own or when combined with other information that We have or are likely to have access to. This includes, but is not limited to, Your name, identification number, contact information, and transaction details.5
By accessing Our Platform, registering for an Account, placing an order, or otherwise providing Us with Your Personal Data, You acknowledge that You have read and understood this Policy and You consent to the collection, use, disclosure, and processing of Your Personal Data in accordance with the terms set out herein.5 If You do not consent to such processing, please do not use Our Services or access Our Platform.
2.2. Information We Collect (Personal Data)
To provide You with Our Services and enhance Your experience on the Platform, We collect various types of Personal Data. The collection of specific and relevant data aligns with the PDPA’s “Notice and Choice Principle,” which mandates transparency regarding data collection practices.6 Our data collection methods and the types of Personal Data collected are detailed below:
The detailed enumeration of data types collected is essential for compliance with the PDPA, ensuring users are fully informed about what information Exbit Store gathers and from which sources. This transparency is a cornerstone of building and maintaining user trust.
Summary of Personal Data Collected, Purposes, and Legal Basis for Processing
Type of Personal Data |
Specific Examples |
Purpose(s) of Collection & Processing |
Legal Basis under PDPA |
Identity & Contact Data |
Full name, email address, phone number, delivery address, billing address, date of birth, gender. |
Account creation & management, order processing & fulfillment, customer support, communication, delivery of goods, fraud prevention, personalization. |
Performance of a contract with you, Consent (for marketing, optional data), Legitimate interests (for service improvement, fraud prevention), Legal obligation. |
Payment Data |
Credit/debit card details (masked), bank account information (for FPX), e-wallet details. |
Processing payments for orders, issuing refunds, fraud prevention. |
Performance of a contract with you, Legal obligation (e.g., financial record keeping). |
Transaction Data |
Details about products purchased, order history, payment amounts, shipping details. |
Order fulfillment, customer support, providing purchase history, analytics for service improvement, personalized recommendations. |
Performance of a contract with you, Legitimate interests (for analytics, personalization). |
Technical Data |
IP address, device type, operating system, browser type, device identifiers. |
Ensuring Platform functionality & security, analytics for service improvement, fraud prevention, personalization. |
Legitimate interests (for security, functionality, analytics), Consent (for certain types of tracking or personalization). |
Usage Data |
Pages viewed, products searched, time spent on Platform, interaction with ads/content. |
Understanding user behavior, improving Platform design & user experience, personalizing content & recommendations, analytics for service improvement, targeted advertising (with consent). |
Legitimate interests (for service improvement, analytics), Consent (for personalization, targeted advertising). |
Location Data |
Precise geolocation data (with consent). |
Providing location-based services (e.g., estimating delivery times, local offers), fraud prevention. |
Consent. |
Marketing & Communications Data |
Your preferences in receiving marketing, communication history. |
Sending promotional offers, newsletters, updates about products & services (with consent/opt-out). |
Consent, Legitimate interests (for communicating important service updates). |
KYC Data (if applicable) |
Government-issued ID (e.g., MyKad, passport). |
Verifying identity for high-value transactions, compliance with anti-money laundering (AML) regulations, fraud prevention (as required by payment processors or law). |
Legal obligation, Legitimate interests (for fraud prevention and security), Consent (if specific consent is sought for this purpose beyond legal/contractual necessity). |
Cookies & Tracking Data |
Information collected via cookies, web beacons, pixels. |
Remembering preferences, session management, analytics, personalization, targeted advertising. |
Consent (for non-essential cookies), Legitimate interests (for essential cookies ensuring functionality). |
This table provides a clear, structured summary of data processing activities, directly supporting the PDPA’s “Notice and Choice Principle” by transparently informing users. While not explicitly found in this format in all competitor policies, it represents a best practice for demonstrating compliance and enhancing user understanding, influenced by global standards like GDPR, and helps Exbit Store internally map its data processing activities to ensure a valid legal basis for each.
2.3. How We Use Your Information
We use the Personal Data We collect for various purposes, all of which are aimed at providing You with a seamless, secure, and personalized shopping experience, and to operate Our business effectively. The use of Your Personal Data is strictly limited to the purposes for which it was collected, or for purposes directly related thereto, in accordance with the PDPA’s “Purpose Limitation Principle”.8 These purposes include:
Linking each use case to a legitimate business purpose or legal obligation strengthens this Policy. The PDPA requires that Personal Data be processed only for lawful purposes directly related to the activities of Exbit Store.6 This articulation of purposes is vital for obtaining informed consent and justifying data processing activities.
2.4. Disclosure of Your Information
Exbit Store may disclose Your Personal Data to third parties in certain circumstances, always in accordance with this Policy and the PDPA’s “Disclosure Principle,” which generally prohibits disclosure without consent unless for specified and legitimate purposes.6 We are committed to ensuring that Your Personal Data is protected when shared with third parties. The categories of third parties to whom We may disclose Your Personal Data include:
We emphasize that disclosure to third parties is undertaken for specific, legitimate purposes and, where feasible and appropriate, under contractual agreements that include obligations of confidentiality and data protection. This aligns with the PDPA’s requirements for safeguarding data even when it is shared with external parties.8 Such transparency helps users understand the circumstances under which their data might be shared, reinforcing trust and ensuring compliance.
2.5. Data Security and Retention
Exbit Store takes the security of Your Personal Data very seriously and implements a range of technical, administrative, and physical security measures designed to protect Your Personal Data from unauthorized access, use, disclosure, alteration, or destruction. These measures are in line with the PDPA’s “Security Principle”.5 Our security measures include:
While We strive to use commercially acceptable means to protect Your Personal Data, it is important to acknowledge that no method of transmission over the Internet or method of electronic storage is 100% secure.5 Therefore, We cannot guarantee its absolute security. We encourage You to also take steps to protect Your Personal Data, such as choosing a strong password, keeping Your password confidential, and logging out of Your Account after use, especially on shared devices.
Data Retention:
In accordance with the PDPA’s “Retention Principle,” Exbit Store will retain Your Personal Data only for as long as it is necessary to fulfill the purposes for which it was collected, or as required or permitted by applicable laws.6 The retention period may vary depending on the nature of the data and the purposes of processing. Key considerations for retention include:
Once Your Personal Data is no longer required for these purposes, We will take reasonable steps to securely destroy or permanently de-identify it. Acknowledging the limits of security while detailing the measures taken presents a realistic and trustworthy approach. Specificity regarding retention criteria, rather than vague statements, is crucial for compliance and user understanding. This assures users that their data is handled with care and not kept indefinitely without a valid purpose.
2.6. Your Rights (as per PDPA 2010)
Under the Malaysian Personal Data Protection Act 2010 (PDPA), You have certain rights concerning Your Personal Data that We hold. Exbit Store is committed to upholding these rights and providing You with the means to exercise them.5 Your rights include:
Exercising Your Rights:
To exercise any of these rights, please contact Our Data Protection Officer (DPO) using the contact details provided in Section 2.11 (“Contact Us”) of this Policy. We will respond to Your request in accordance with the PDPA and within the timeframes stipulated by law.
Please note that:
Clearly empowering users with their data rights is a core tenet of the PDPA and builds significant trust. The process for exercising these rights must be straightforward and accessible, demonstrating Exbit Store’s respect for user autonomy over their data and its commitment to PDPA compliance.
2.7. Cookies and Tracking Technologies
Exbit Store uses cookies and similar tracking technologies (such as web beacons, pixels, and scripts) to enhance Your experience on Our Platform, analyze usage, personalize content, and for advertising purposes.5 A cookie is a small text file that is stored on Your computer or mobile device when You visit a website.
Types of Cookies We Use and Their Purposes:
Managing Your Cookie Preferences:
Most web browsers automatically accept cookies, but You can usually modify Your browser settings to decline cookies if You prefer.14 You can typically find these settings in the “options” or “preferences” menu of Your browser. Disabling cookies may, however, affect Your ability to use certain features of the Platform. For example, You may not be able to log in to Your Account or make purchases.
We will provide You with clear information about Our use of cookies and, where required by law, obtain Your consent before placing non-essential cookies on Your device. You can manage Your consent preferences for cookies through a cookie consent banner or a settings panel on Our Platform. A dedicated section on cookies improves transparency and user control, which is increasingly expected and often required by privacy regulations worldwide.
2.8. International Data Transfers (If Applicable)
Your Personal Data may be transferred to, stored at, or processed in a jurisdiction outside of Malaysia if, for example, Our third-party service providers (such as cloud hosting providers or payment processors) are based overseas, or if Our group companies operate in other countries.5
If We transfer Your Personal Data out of Malaysia, We will take appropriate steps to ensure that Your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the Malaysian PDPA. This may include:
By using Our Platform and Services, You understand and consent to the transfer of Your Personal Data to these locations, subject to the safeguards mentioned above. This clause is critical for PDPA compliance if Exbit Store utilizes global cloud services or international third-party providers, informing users about potential cross-border data flows and assuring them of protective measures.
2.9. Children’s Privacy / Minors
Exbit Store’s Platform and Services are not directed at or intended for use by individuals under the age of 18 (“Minors”) without the consent and supervision of a parent or legal guardian.7 We do not knowingly collect Personal Data from Minors without verifiable parental or guardian consent.
If You are a Minor, You may only use Our Platform and Services with the involvement, consent, and supervision of Your parent or legal guardian. Your parent or legal guardian must agree to be bound by Our Terms of Use and this Privacy Policy on Your behalf.
If We become aware that We have inadvertently collected Personal Data from a Minor without the necessary parental or guardian consent, We will take reasonable steps to delete such information from Our records promptly. The PDPA requires parental consent for processing minors’ data 7, making this clause essential for legal protection and responsible data handling. It protects both Minors and the business by setting clear boundaries for data collection from underage users.
If You are a parent or legal guardian and believe that Your child has provided Us with Personal Data without Your consent, please contact Us using the details in Section 2.11 (“Contact Us”).
2.10. Changes to This Privacy Policy
Exbit Store reserves the right to modify or update this Privacy Policy at any time to reflect changes in Our practices, Services, or legal requirements.5 We will notify You of any material changes to this Policy by posting the updated Policy on Our Platform, and/or by sending You an email notification to the email address associated with Your Account, or through other appropriate communication channels.
We encourage You to review this Policy periodically for any changes. The “Last Updated” date at the top of this Policy indicates when it was last revised. Your continued use of the Platform or Services after any changes to this Policy are posted will be deemed acceptance of those changes. A dynamic business environment and evolving laws necessitate policy updates, and a clear process for notification is important to keep users informed.
2.11. Contact Us
If You have any questions, concerns, or complaints regarding this Privacy Policy, Our data protection practices, or if You wish to exercise Your rights with respect to Your Personal Data, please contact Our Data Protection Officer (DPO) at:
Kompotech Sdn. Bhd.
Attn: Data Protection Officer
Email: [[email protected]] (or a dedicated DPO email address)
Phone: [Insert Phone Number, if applicable]
Providing a dedicated contact point for privacy concerns is crucial for PDPA compliance and user trust, facilitating communication and demonstrating Exbit Store’s commitment to addressing privacy issues.
The Policies detailed herein – encompassing Our Privacy Policy, Refund Policy, Terms of Use, Payment Terms, and Delivery Terms – are established by Kompotech Sdn. Bhd. for the operation of Exbit Store (https://exbit.store). They are designed to create a safe, fair, transparent, and legally compliant environment for all Users of the Platform.
Exbit Store is committed to upholding the highest standards of business conduct, adhering to all applicable laws and regulations in Malaysia, including but not limited to the Personal Data Protection Act 2010, the Consumer Protection Act 1999, and the Electronic Commerce Act 2006. Our aim is to provide an excellent and trustworthy e-commerce experience.
Users are encouraged to review these Policies periodically, as they may be updated from time to time to reflect changes in Our business operations, services, or legal obligations. Your continued use of the Exbit Store Platform signifies Your acceptance of these Policies and any amendments thereto.
We value Your trust and patronage. Should You have any questions or require clarification regarding any aspect of these Policies, please do not hesitate to contact Us through the relevant channels provided within each policy document. A concluding section like this reinforces the professionalism and user-centric approach of Exbit Store, leaving the user with a final impression of commitment to a well-regulated and fair platform.