Dokumen ini dalam Bahasa Inggeris. Versi Bahasa Malaysia penuh, ditulis fasal demi fasal selari dengan dokumen ini, ada di Dasar Privasi (Bahasa Malaysia). Ia ditulis dengan teliti, bukan diterjemah secara mesin, dan akan disemak oleh peguam bela & peguam cara berlesen. Dokumen ini menerangkan hak anda di bawah Akta Perlindungan Data Peribadi 2010.
Jika ada bahagian yang anda tidak faham, atau anda ingin mengakses, membetulkan, atau memadam data peribadi anda, hubungi kami di legal@rorobean.com.my. Kami akan terangkan dalam Bahasa Malaysia.
This document is in English. A full Bahasa Malaysia version, written clause by clause to match it, is at privasi.html; both will be reviewed by a licensed advocate & solicitor. If any part is unclear, or you wish to access, correct, or delete your personal data, contact us.
IMPORTANT: This document is a working draft. It is NOT legal advice and has NOT been reviewed by a qualified Malaysian lawyer. Before publication, it must be reviewed by a licensed advocate & solicitor familiar with the Personal Data Protection Act 2010, the Personal Data Protection (Amendment) Act 2024, and the Guidelines on Cross Border Personal Data Transfer issued 29 April 2025. The data-retention periods in Section 6 are proposed starting points, not settled policy — a reviewing lawyer should confirm each against the specific statutory record-keeping obligations that apply (including the Income Tax Act 1967) before this document is relied upon.
This Privacy Policy explains how Eimir Farehah Network Sdn Bhd (SSM Registration No: 202201022331), trading as "RoroBean" ("RoroBean", "we", "us", "our"), collects, uses, discloses, and protects personal data in connection with the RoroBean mobile and web application and related services (the "Platform"), in accordance with the Personal Data Protection Act 2010 ("PDPA") of Malaysia. This Policy forms part of, and should be read together with, our Terms and Conditions.
1.1Account data — your name, email address, phone number, and password, collected when you register as a Customer or a Bean Owner.
1.2Company data — for users registering as a company, the company name, SSM registration number, and tax identification details, where applicable.
1.3Booking data — delivery and collection addresses, booking dates, special instructions, and communications relating to a specific Booking.
1.4Payment data — Bookings are paid through a third-party payment gateway. RoroBean does not collect or store your full card or online-banking details when you pay; the payment gateway provider processes that data under its own privacy policy, and RoroBean receives only confirmation that a payment succeeded and the amount involved. The only bank account details RoroBean holds about a Customer are those described in Section 1.11, given by you for a refund.
1.5Bean Owner payout data — bank account name and number, used solely to pay out a Bean Owner's earnings, and tax residency information, where required for tax reporting purposes.
1.6Verification data — for Bean Owners, identity document images, a selfie photograph and a short live face check, and the details read from the identity document, collected through a third-party identity verification provider to confirm that a Bean Owner is who they claim to be before they can accept Bookings. The face images and the measurements derived from them are biometric data: see Section 1.13.
1.7Job evidence — photographs taken by a Bean Owner or driver at the point of delivery or collection of a RoRo bean, used to confirm the condition and timing of the service and to resolve disputes.
1.8Location data — an approximate delivery location for booking purposes, and, where permission is granted on a driver's device, a location reading captured at the moment a delivery or collection is stamped.
1.9Support and dispute data — the content of any support ticket, complaint, or dispute you raise through the Platform, including any related booking reference.
1.10Technical data — IP address, device and browser type, and pages visited on the Platform, collected automatically for security and troubleshooting purposes.
1.11Refund data — if you are a Customer and cancel a paid Booking, we ask for the name of your bank, the name of the account holder, and your bank account number, so that we can pay any refund to you by bank transfer. We collect this only when a refund is due, and use it only to pay that refund and to check that the account belongs to you. We may ask you for proof that the account is yours.
1.12Cancellation records — the reason you give for cancelling, the stage of the Booking when it was cancelled, the amount you paid, the cancellation charge (if any) and how it is shared, the refund amount, and the dates and references of each step (request, approval, payment).
1.13Biometric data — to confirm that the person on the identity document is the person completing the check, the identity verification provider compares your selfie with the photograph on your document and checks that a live person is present (a "liveness" check). This produces measurements derived from your face. This is biometric data, a kind of sensitive personal data under the PDPA. We use it only for this check and for no other purpose. RoroBean does not keep your face images or facial measurements itself, and has not asked the provider to keep a reusable facial template.
1.14Support attachments — if you attach pictures to a support ticket (up to 5 JPEG pictures), we hold those pictures with the ticket. Each picture is redrawn in your browser before it is uploaded, which removes the location, camera and date details stored inside the file, but it still shows whatever is visible in the picture itself. Please do not attach identity cards, bank cards or other personal documents; a support ticket is not the place for them, and we do not use it to verify identity (Section 1.6).
1.15Bean Owner profile — a Bean Owner may add a profile photograph and a short introduction (up to 300 characters). These are optional. They are shown to Customers who are looking at that Bean Owner's Beans or booking one (Section 4.7). The photograph is kept in a storage area that anyone who has its web address can open, so please choose a picture you are content for Customers to see. The introduction may not contain an email address, web address or telephone number.
2.1To create and manage your account, and to verify a Bean Owner's identity and eligibility before they may accept Bookings.
2.2To process a Booking, including sharing the minimum booking and contact details necessary between a Customer and a Bean Owner so that a Booking can be fulfilled.
2.3To process payments and Bean Owner payouts, and to meet our own tax and financial record-keeping obligations as a Malaysian company.
2.4To operate the loyalty and rank programs described in the Terms and Conditions.
2.5To respond to support requests and to investigate and resolve disputes between a Customer and a Bean Owner.
2.6To detect and prevent fraud, abuse, or activity that breaches the Terms and Conditions.
2.7To send transactional communications relating to a Booking, an account, or a support request — for example, a booking confirmation or a reply to a support ticket. RoroBean does not send marketing communications without separate consent.
2.8To comply with a legal obligation, including a request from a Malaysian regulatory or tax authority.
2.9To process a cancellation: to work out the cancellation charge, to share it with the Bean Owner as the Terms and Conditions provide, to obtain the approval of RoroBean's finance officer for a refund, to pay the refund by bank transfer, and to keep the records of each step.
2.10To verify a Bean Owner's identity by comparing the face on the identity document with a live selfie, and to record the outcome of that check. Biometric data is used only for this purpose.
2.11To look at the pictures attached to a support ticket, only to understand and resolve that ticket.
2.12To show a Bean Owner's optional profile photograph and introduction to Customers, so that a Customer can see who they are booking from.
3.1By registering an account, you consent to the collection, use, and disclosure of your personal data as described in this Policy, in accordance with the Notice and Choice Principle under the PDPA.
3.2Where processing is necessary to perform a Booking or another contract you have entered into through the Platform — for example, sending you a booking confirmation, or sharing your delivery address with the Bean Owner fulfilling that Booking — that processing takes place because it is necessary for that contract, whether or not separate consent is additionally given.
3.3You may withdraw consent for a purpose that is not necessary to an existing contract at any time by contacting us, though this may affect your ability to use certain features of the Platform.
3.4Biometric data — before we ask you to take part in the identity check described in Section 1.13, we ask for your separate and explicit consent, in a box that you tick for that purpose alone. It is not covered by the general consent in Section 3.1. We record the date and the wording you agreed to. You may refuse; if you do, we cannot verify you and you cannot accept Bookings as a Bean Owner. You may withdraw consent at any time by contacting us. We will then instruct the provider to erase your verification data (Section 8.6). A withdrawal does not undo checks already carried out and does not affect records we must keep under Section 6.
4.1Between Customer and Bean Owner — the minimum contact and location details necessary to fulfil a Booking are shared between the Customer and the Bean Owner assigned to it.
4.2Service providers — RoroBean engages third-party service providers to operate the Platform, including cloud hosting and database providers, email delivery providers, payment gateway providers, and identity verification providers. Each is given access only to the personal data necessary to perform its specific function, and is bound by confidentiality and data protection obligations. RoroBean does not sell personal data to any third party.
4.3Legal and regulatory disclosure — personal data may be disclosed where required by Malaysian law, by a court order, or to a regulatory or tax authority, including in connection with our own statutory tax reporting obligations as an employer or payer of income to Bean Owners.
4.4Business transfer — if RoroBean is involved in a merger, acquisition, or sale of assets, personal data may be transferred as part of that transaction, subject to this Policy continuing to apply to it.
4.5Cancellations — when a Booking is cancelled, the Bean Owner is told that it was cancelled, the stage, and the Bean Owner's share of any cancellation charge. The Bean Owner does not receive your bank account details. Your bank account details are disclosed only to RoroBean's finance officer and authorised administrators who approve or pay your refund, and to the bank that carries out the transfer.
4.6Identity verification provider — the provider receives your identity document images and selfie only to carry out the check and return the result to us. It acts on our instructions. We have switched off the provider's right to use our users' verification data to train its own models. The provider may still process limited, pseudonymised data to protect its service against fraud and security threats, as its terms with us describe. We instruct the provider to delete the verification session once the final decision is made, and in any event within one month.
4.7Support attachments and Bean Owner profiles — pictures attached to a support ticket are seen only by the person who raised the ticket and by RoroBean administrators who handle support; they are not shown to a Bean Owner or any other Customer. A Bean Owner's profile photograph and introduction are shown to Customers on the booking page for that Bean Owner's Beans, and, because of how the photograph is stored (Section 1.15), may be opened by anyone who has its web address.
5.1Some of the service providers described in Section 4.2 process personal data on servers located outside Malaysia. Where this occurs, the transfer is made on one or more of the following bases permitted under Section 129 of the PDPA (as amended by the Personal Data Protection (Amendment) Act 2024) and the Guidelines on Cross Border Personal Data Transfer issued by the Personal Data Protection Commissioner on 29 April 2025: (a) the transfer is necessary for the performance of a contract between you and RoroBean, such as delivering a booking confirmation or a support reply to your own email address; (b) the recipient jurisdiction is assessed as having data protection law substantially similar to, or providing a level of protection at least equivalent to, the PDPA; or (c) you have given consent to the transfer.
5.2RoroBean's own core database is hosted in Singapore. Where any other service provider processes data outside Malaysia or Singapore, RoroBean takes reasonable steps to ensure that provider does not process personal data in a manner that would contravene the PDPA.
5.3The identity verification provider in Section 4.6 processes verification data mainly on servers in the European Economic Area. The company we contract with is established in the United States, and the provider may use sub-processors in other countries under standard contractual clauses. Verification data is transferred outside Malaysia only on the basis of your explicit consent under Section 3.4 and the contractual safeguards we have agreed with the provider. On request, we will tell you who the provider is and where it processes your data.
Personal data is kept only for as long as necessary for the purpose it was collected for, or as long as Malaysian law requires it to be kept, whichever is longer. The following are the retention periods RoroBean currently works to; a reviewing lawyer should confirm each is correctly matched to its underlying legal basis before this Policy is published.
| Category | Retention period |
|---|---|
| Account and profile data | Duration of account, plus up to 24 months after closure or last activity |
| Booking, invoice, and payout records | 7 years from the transaction date |
| Bean Owner verification (KYC) records: the outcome, its reference number, the dates and the reviewer's decision | 7 years from the end of the Bean Owner relationship |
| Identity document images, selfie and facial data held by the verification provider | Deleted from the provider once the verification decision is final, and in any event within one month. RoroBean does not keep a copy. |
| Customer refund bank account details | Kept in full only until the refund is paid (or rejected). 12 months after that, the account number is reduced to its last four digits and the account holder's name is removed. The refund record itself (amounts, dates, bank reference) is kept for 7 years as a financial record. |
| Support tickets and disputes | 3 years from resolution |
| Pictures attached to support tickets | 12 months after the ticket is resolved or closed, then deleted automatically. The text of the ticket is kept as stated above. |
| Bean Owner profile photograph and introduction | While shown on the Platform. A Bean Owner may replace or remove them at any time, and the photograph file is then deleted. We also delete them on request (Section 8.7). |
| Job evidence photographs | 3 years from the booking date |
| Security and access logs | 12–24 months |
| Routine system backups | Rolling window of up to 90 days after deletion from live systems |
6.1A period above may be extended where personal data is needed to comply with a legal obligation, to establish or defend a legal claim, or for an active dispute or fraud investigation, until that matter is concluded.
6.2The 7-year periods for financial and verification records reflect Malaysia's statutory business record-keeping requirements, including under the Income Tax Act 1967, and are not shortened by an earlier account closure.
7.1RoroBean applies role-based access controls so that personal data is visible only to the account it belongs to, or to the other party to a Booking to the extent necessary to fulfil it. Sensitive fields, including payout and verification status, are protected by database-level rules that cannot be bypassed from the application alone.
7.2Changes to sensitive data, such as a Bean Owner's bank account, are logged and the affected user is notified, so that an unauthorised change is both recorded and visible to the person it concerns.
7.3No method of transmission or storage is completely secure. While RoroBean takes reasonable technical and organisational measures to protect personal data, it cannot guarantee absolute security.
7.4Refund bank account details are shown in full only to the Customer who gave them and to RoroBean's finance officer. Other administrators see only the last four digits until the finance officer has approved the refund. Every approval, rejection and payment is recorded with who did it and when.
7.5Personal data breach — if a personal data breach occurs that causes, or is likely to cause, significant harm, RoroBean will notify the Personal Data Protection Commissioner and the affected individuals as the PDPA requires, will tell affected individuals what happened, what data is involved and what they can do to protect themselves, and will keep a record of the breach and of the steps taken.
8.1Subject to the PDPA, you have the right to: request access to the personal data RoroBean holds about you; request correction of inaccurate or incomplete personal data; withdraw consent to processing that is not necessary for an existing contract; and request that RoroBean limit the processing of your personal data.
8.2To exercise any of these rights, contact us at legal@rorobean.com.my. RoroBean may need to verify your identity before acting on a request, and may decline a request to the extent permitted by the PDPA — for example, where data must be kept to meet a legal obligation described in Section 6.
8.3You may also lodge a complaint with the Department of Personal Data Protection Malaysia if you believe your personal data has been processed unlawfully.
8.4Data portability — where the PDPA gives you the right, you may ask RoroBean to transmit your personal data to another data controller of your choice in a structured, commonly used and machine-readable format, where this is technically feasible.
8.5RoroBean will answer a request to access or correct personal data within the time the PDPA allows (21 days), and will tell you if more time is needed and why.
8.6Verification data — you may ask us at any time to have your identity verification data erased from the provider. We will send the erasure instruction to the provider and tell you when it is confirmed, subject to the records we must keep under Section 6.
8.7Support attachments and profile photograph — you may ask us at any time to delete the pictures attached to your support tickets before the period in Section 6 ends, or to delete your profile photograph and introduction. A Bean Owner can also remove them without asking, on the profile page.
9.1The Platform uses only the cookies and local storage necessary to keep you signed in and to remember your language preference. RoroBean does not use advertising or cross-site tracking cookies, and transactional emails sent by the Platform do not include open or click tracking.
10.1The Platform is not directed at, and does not knowingly collect personal data from, individuals under the age of 18, consistent with the eligibility requirement in the Terms and Conditions.
11.1This Policy may be amended from time to time. Material changes will be notified to users through the Platform. Continued use of the Platform after such notice constitutes acceptance of the amended Policy.
Eimir Farehah Network Sdn Bhd No 32, Jalan Pulau Kapas U10/86, Bukit Bayu, 40170 Shah Alam, Selangor, Malaysia SSM Registration No: 202201022331 For questions about this Privacy Policy, or to exercise a right described in Section 8, contact us at legal@rorobean.com.my. Officer responsible for personal data protection: Eimir Azmi Md Noh, Chief Executive Officer, at the same address.
REMINDER: This draft is a starting point only. Before publishing this Privacy Policy or relying on it in any live transaction, have it reviewed and finalized by a licensed Malaysian advocate & solicitor.