Privacy Policy

1. Personal Data We Collect

Account and identity data. Name, username, date of birth, nationality, country of residence, address, email, telephone number, profile image, account identifiers and authentication records.

Verification and compliance data. Government-issued identity-document details and images, selfie or liveness images, facial-verification results, occupation, source-of-funds information, tax or residency information, sanctions and politically exposed person screening results, risk assessments and communications about verification. Verification may be performed by providers such as Sumsub. Depending on the integration, WoWo may receive a verification result and selected fields rather than all raw verification data.

Financial and transaction data. Balances displayed in the App, funding source, payment and payout details, merchant and recipient information, card metadata, billing address, transaction amount, currency, exchange rate, fee, status, refund, chargeback and provider reference. Full card credentials may be tokenized and held by card providers rather than WoWo.

Digital-asset and blockchain data. Wallet addresses, blockchain network, asset type, transaction hash, amount and related public-ledger information. Public blockchain records are visible to others and generally cannot be changed or deleted.

Device, network and security data. Device model, operating system, app version, language, time zone, IP address, mobile-network information, device and session identifiers, login and authentication events, security signals, crash data, diagnostics and performance logs.

Camera, photos and location. With permission, the App may use the camera to scan payment QR codes or identity documents, allow you to upload images, and use approximate or precise location for merchant availability, compliance, fraud prevention or service support. We request permissions when needed and you may change them in device settings.

eSIM and travel data. Device compatibility, destination, selected plan, activation code and status, data allowance, validity, connectivity and support information received from the eSIM provider.

Rewards, referral and partner data. Membership level, points, qualifying activity, reward status, redemption history, invitation code and link, referral relationship, attribution, commission and partner application or performance data.

Communications and user content. Chat messages, community posts, images, reports, blocked-user lists, customer-support requests, call or message metadata, survey responses and other content you submit. Content may be reviewed for safety, support, fraud prevention and enforcement.

Cookies, SDKs and analytics. On wowo.io and where used in the App, cookies, SDKs and similar technologies may collect product interaction, session, attribution, crash and performance data. We do not use personal data for cross-app or cross-site tracking without the permission required by the operating system, app-distribution platform and applicable law.

2. How We Collect Data

We collect data directly from you; automatically from your device and use of the Services; from merchants, card issuers, payment processors, banks, wallet and mobile-money providers, custodians, blockchain networks, eSIM and rewards providers; from identity, fraud and compliance providers; from referral or partner users; and from public or legally permitted sources.

If you share an invitation using your device's native share function, the operating system may handle your contacts without WoWo uploading your address book. We will access contacts only if a feature requires it, you grant permission and the use is disclosed.

3. Why We Use Personal Data

We use personal data to create and secure accounts; authenticate users; provide, personalize and support the Services; determine eligibility and regional availability; process and reconcile transactions; issue receipts and notifications; operate cards, remittance, eSIM, rewards, referrals and community features; prevent fraud and abuse; perform KYC, sanctions and regulatory checks; resolve disputes; maintain records; improve reliability and design; communicate service information; and comply with law.

Where applicable, processing is based on performance of our contract with you, compliance with legal obligations, your consent, and our or a third party's legitimate interests in security, service improvement, fraud prevention, customer support and responsible business operations. Where sensitive or biometric data requires explicit consent, the relevant verification provider or WoWo will request it before processing.

4. Automated Risk and Eligibility Decisions

We and our providers may use automated rules, device signals, transaction patterns and verification results to identify fraud, determine eligibility, set limits, hold or reject transactions and prioritize manual review. These tools may materially affect access to a regulated feature. You may contact support to request information or human review where required by applicable law.

5. How We Share Personal Data

We share personal data only as reasonably necessary with appointed custodians or trustees; banks, payment processors, QR-payment providers, card issuers and processors; remittance, payout, e-wallet and mobile-money providers; identity and compliance providers, including Sumsub where enabled; eSIM and telecommunications providers; rewards, voucher and fulfilment providers; cloud hosting, cybersecurity, analytics, communications and customer-support providers; professional advisers, auditors and insurers; and Apple, Google or other app-distribution platforms.

We may share data with regulators, law-enforcement authorities, courts, payment networks or other persons where required by law, to protect rights and safety, investigate fraud or enforce our agreements. We may transfer data in connection with a merger, financing, restructuring or sale, subject to confidentiality and applicable law.

A provider that independently determines how it processes data is responsible for its own processing. We require processors acting on our instructions to apply appropriate confidentiality, security and data-protection safeguards. We do not sell personal data.

6. International Transfers

WoWo serves users through providers and infrastructure that may be located outside Malaysia or your country. Personal data may therefore be transferred to and processed in other jurisdictions. We use conditions and safeguards permitted by applicable law, which may include contractual protections, due diligence, security controls, adequacy findings, necessity for the requested service or consent where required.

7. Data Retention

We retain personal data only for as long as needed for the purposes described in this Policy, including while your account is active and for periods required by anti-money laundering, payments, card-network, tax, audit, consumer-protection, dispute and other legal obligations.

Retention depends on the data type, sensitivity, transaction status, legal requirements, risk of harm and whether a dispute or investigation is ongoing. After account deletion, we delete or anonymize data that is no longer required. Some records may remain in secure backups until overwritten. Public blockchain records cannot be deleted by WoWo. Independent providers retain data under their own legal obligations and policies.

8. Security

We use administrative, technical and physical safeguards designed to protect personal data, including access controls, encryption in transit, logging, monitoring, secure development and vendor review. No system is completely secure. Protect your device and credentials and contact us immediately if you suspect unauthorized access.

We maintain incident-response procedures and will notify affected individuals and authorities where required by applicable data-breach notification law.

9. Your Choices and Rights

Subject to applicable law, you may request access to, correction of, or a copy of personal data; withdraw consent; object to or restrict certain processing; request deletion or portability; opt out of direct marketing; and complain to the relevant data-protection authority.

You can update certain information in the App and manage device permissions through iOS or Android settings. Marketing messages include an unsubscribe method, although we may still send essential security, account and transaction communications.

We may need to verify your identity before fulfilling a request. Rights may be limited where retention or processing is required by law, necessary to protect another person, or subject to legal privilege or other lawful exceptions.

10. Account and Data Deletion

You may initiate account deletion in the App through Settings > Account & Security > Delete Account. You may also request deletion by sending an email to contact@wowo.io without reinstalling the App. The app interface should provide a way to submit a deletion request.

Deletion may require identity verification, confirmation of the request, settlement of pending transactions and instructions concerning eligible balances, active cards, eSIM plans, remittances, disputes or other active Services. We will explain any necessary steps and complete the request within a reasonable period, subject to applicable law.

Account deletion removes the account and associated data that WoWo is not legally required to retain. It does not automatically erase records held by independent providers, public blockchain entries, or records that must be preserved for anti-money laundering, regulatory compliance, security, fraud prevention, disputes, tax, audit or transaction integrity. Where appropriate and legally permitted, we will request processors acting on our instructions to delete relevant data.

11. Children's Privacy

The Services are not directed to persons under 18 and we do not knowingly allow them to use financial or regulated features. If you believe a minor has provided personal data, contact us so we can investigate and take appropriate action.

12. Third-Party Services, App Stores and Links

The App may link to or integrate third-party services. Their privacy practices are governed by their own notices. Review those notices before providing data or using the service. WoWo is not responsible for an independent provider's privacy practices, except to the extent required by law.

Apple, Google and other app-distribution platforms may independently process store account, download, device, diagnostics, payment or usage information under their own privacy policies. WoWo does not control data collected independently by those platforms. Information they provide to WoWo is handled under this Policy.

13. Changes to This Policy

We may update this Policy to reflect changes in the Services, providers, technology or law. We will update the effective date and provide additional notice of material changes where required. If consent is required for a new purpose, we will request it.

14. Contact and Complaints

Privacy Contact / Data Protection Officer (where appointed)
WoWo Digital Sdn. Bhd.
Registration No. 202601023578 (1685675-M)
No. 25, Wisma SCMS, Jalan BP 7/12, Bandar Bukit Puchong, 47120 Puchong, Selangor, Malaysia
Email: contact@wowo.io
Telephone: +60 19-208 8328
Website: https://wowo.io

You may also lodge a complaint with the Personal Data Protection Commissioner of Malaysia or the competent authority in your country. We encourage you to contact us first so we can address the concern.