EnglishBahasa Melayu
Version 1.0 · Effective date: 19 June 2026 · Last updated: 19 June 2026
This is the privacy policy (“Privacy Policy”) of GAVO Sdn Bhd issued pursuant to Section 7 of the Personal Data Protection Act 2010 (“PDPA”). GAVO Sdn Bhd is a licensed moneylender under the Moneylenders Act 1951 (licence no. WL7948/14/01-3/250128), carrying on the business of lending money to individuals.
Any reference to “we”, “us” or “our” shall refer to GAVO Sdn Bhd (“GAVO”), its directors, officers, employees and/or our Data Processor.
Unless otherwise defined, all capitalised words used in this Privacy Policy shall have the meaning as defined in the PDPA.
This Privacy Policy explains the manner in which we record, store, process, disclose, transfer and otherwise use your personal data collected in connection with your enquiry, your application for, and your use of, our loan products and services, as well as the rights available to you as a Data Subject on the handling of personal data. This Privacy Policy applies to any person whose personal data is provided to us, possessed and/or processed by us and/or by our Data Processor, whether now or in the future.
Introduction
1.It is required under the PDPA to inform you, a Data Subject, of your rights in respect of your personal data that is being collected and processed by us and the purposes of the data processing. The PDPA also requires us to obtain your consent to the processing of your personal data.
2.By providing your personal data to us, by using our website at gavofund.com (the “Website”), or by applying for or holding a loan with us, you declare that you have read and understood this Privacy Policy and have agreed to us processing your personal data in accordance with this Privacy Policy.
3.You are responsible for the accuracy and completeness of all personal data provided by you to us, and that none of such personal data is misleading or out of date. Should there be any changes or updates to your personal data, you will promptly update us in writing.
Description of Personal Data
4.We and/or our Data Processor may possess and/or process your “personal data”, which includes any information that relates (directly or indirectly) to you to the extent that you are identifiable from that information and other information, such as name, gender, occupation, race, nationality, marital status, residential or correspondence address, contact number, identification card number, passport number, date of birth, income and employment details, bank account and statement details, existing financial commitments, credit history and credit information, loan application and repayment details, photograph and signature, and such other information you provide that relates to you but is not already available in the public domain. The types of personal data collected depend on the purpose of collection.
Sources of Your Personal Data
5.Your personal data may be collected from you during your dealings with us by any mode of communication, including communications or correspondence with us, your use of our Website, and the documents you submit in support of a loan application.
6.In addition, we may also collect, receive, store and process your personal data which is provided or made available by any third parties, including credit reporting agencies and credit reference bodies (such as CTOS, Experian and CCRIS), your employer or bankers (for verification), and regulatory and law enforcement authorities, for reasons including the Purposes stated in Clause 7 below, the delivery of our services and/or to comply with our legal and regulatory obligations.
Purpose of Collection and Processing of Your Personal Data
7.We and/or our Data Processor may process your personal data collected for the following purposes:
(a)to assess and verify your identity, and to process and analyse your personal data either individually or collectively with other individuals;
(b)to assess your eligibility and your ability to repay, and to evaluate, process and decide on your loan application;
(c)to conduct credit checks and credit assessments, including obtaining, verifying and reviewing credit reports and credit information from credit reporting agencies (see the section “Credit Reporting and Consent” below);
(d)to carry out know-your-customer, due diligence, anti-money laundering and counter-financing of terrorism checks under the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (“AMLA”) and related guidelines;
(e)to enter into, administer, manage and maintain your loan and your relationship with us, including disbursement, billing, and the collection and servicing of repayments;
(f)to respond to your enquiries or resolve any issues which may arise in connection with any dealings with us;
(g)to administer and process any payments related to your loan or our services;
(h)to recover any amounts owing to us, including through debt collection agents and legal proceedings;
(i)to provide you with newsletters, updates or information about our products and services, where you have consented;
(j)to monitor, review and improve our services and our Website;
(k)to share any of your personal data with our auditors for our internal audit and reporting purposes;
(l)to detect, investigate and prevent any fraudulent, prohibited or illegal activity, omission or misconduct;
(m)to meet any applicable legal or regulatory requirements and to make disclosures under the requirements of any applicable laws, regulations, directions, court orders, by-laws, guidelines, circulars or codes applicable to us, including those of the Ministry of Housing and Local Government (KPKT) and any successor authority such as the Consumer Credit Commission;
(n)to comply with or as required by any request or direction of any governmental authority, or to respond to requests for information from public agencies, ministries, statutory bodies or other similar authorities;
(o)to enforce or defend our rights and your rights under, and to comply with our obligations under, applicable laws, legislation and regulations;
(p)for the registration of a user account with us on our Website or customer portal as we may create and improve from time to time;
(q)for our storage and hosting back-up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Malaysia;
(r)to process and analyse your personal data using artificial intelligence (“AI”) and other technology-assisted tools operated by third-party technology service providers, for the purpose of assisting our personnel in assessing applications and delivering our services, whereby all outputs generated through such tools are reviewed and approved by our authorised personnel before any decision is communicated to you (see the section “Use of Artificial Intelligence and Technology-Assisted Tools” below); and/or
(s)for other purposes required to operate, maintain and better manage our business and your relationship with us,
(collectively referred to as the “Purposes”).
8.You agree and consent to us using and processing your personal data for the Purposes. If you do not consent to us processing your personal data for any one of the Purposes, please inform us using our contact details below.
Disclosure / Transfer of Your Personal Data
9.We may disclose your personal data to the following third parties, for any of the Purposes:
(a)credit reporting agencies and credit reference bodies (including CTOS, Experian and CCRIS), and other financial institutions;
(b)regulators, government and law enforcement authorities, including KPKT, Bank Negara Malaysia and any successor authority such as the Consumer Credit Commission;
(c)any party as may be directed by you with notice to us from time to time;
(d)any person under a duty to keep your personal data confidential whom we have engaged to discharge our obligations to you;
(e)any party in relation to or in connection with any existing or prospective legal proceedings, and debt collection agents engaged to recover amounts owing to us;
(f)data centres and/or servers located within or outside Malaysia for data storage purposes;
(g)storage facility and records management service providers;
(h)payment channels including banks and financial institutions for the purpose of assessing, verifying, effecting and facilitating payment of any amount due to or from us in connection with your loan;
(i)our business partners, third-party service providers (including professional advisers, auditors and insurers), contractors, agents and representatives, on a need-to-know basis, who provide related services in connection with our business or discharge one or more of the Purposes;
(j)third-party technology service providers (including providers of AI and data-processing tools) engaged by us, subject to binding data processing agreements; and/or
(k)any party to whom we transfer or propose to transfer any of our rights or obligations, or any other person reasonably requiring the same in order for us to operate and maintain our business or carry out the Purposes or as instructed by you.
We will take reasonable measures to procure compliance by any foreign entities handling your personal data so as to adequately protect your confidentiality and privacy. Save for the above, we will not sell, transfer or disclose any of your personal data to any third party without your consent.
Credit Reporting and Consent
10.Pursuant to the Credit Reporting Agencies Act 2010 and the Central Bank of Malaysia Act 2009, you consent to GAVO obtaining, verifying, processing and disclosing your personal data and credit information from and to credit reporting agencies and credit bureaux, including CTOS Data Systems Sdn Bhd (“CTOS”), Experian Information Services (Malaysia) Sdn Bhd (“Experian”) and the Central Credit Reference Information System (“CCRIS”) maintained by Bank Negara Malaysia, for purposes including credit evaluation, account monitoring and review, debt recovery and the preparation of legal documentation.
11.This consent remains in force for as long as you maintain an account or transaction with us, or any amount remains outstanding.
Your Rights for Access and Corrections, Inquiries and Complaints
12.To the extent permitted by applicable law and upon payment of the charges prescribed under the PDPA, you may request access to or a copy of your personal data kept with us for the purposes of checking, correcting or updating such personal data.
13.You have the right to update or correct your personal data kept with us by contacting us at our contact details below.
14.Subject to any applicable legal restrictions and/or contractual conditions, you have the right at any time to withdraw (in full or in part) your consent previously given to us to process your personal data for any of the Purposes or to disclose to any of the parties mentioned in Clause 9, by giving us reasonable notice of your intention to withdraw. Please note that withdrawing your consent may mean that we are unable to continue providing our services to you or to administer any existing loan.
Your Rights to Data Portability
15.You may, where technically feasible, request us to transmit your personal data that we possess to another similar service provider of your choice in a structured, commonly used and machine-readable format.
16.Upon receiving your request, we shall endeavour to complete the transmission of your personal data within such reasonable period as may be prescribed under the PDPA.
Personal Data of Persons Other Than You
17.In relation to personal data of any third party that you provide to us, such as your spouse, family members or other dependants, guarantors, referees or emergency contacts, you confirm that you have obtained their consent to the processing (including disclosure and transfer) of their personal data in accordance with this Privacy Policy.
Consequences of Not Providing Your Personal Data
18.It may be obligatory or voluntary for you to provide, and for us to collect and process, your personal data. Where it is mandatory for you to provide your personal data, and if you fail or choose not to provide it, or do not consent, or subsequently withdraw your consent to this Privacy Policy, we may not or will not (as the case may be) be able to assess your application, provide our services to you, or administer any existing loan.
Retention and Security of Your Personal Data
19.We will only process your personal data in accordance with the PDPA, the applicable regulations, guidelines and orders made under the PDPA, and any statutory amendments or re-enactments made from time to time, as well as this Privacy Policy.
20.Your personal data is retained for the duration of your relationship with us and for as long as the Purposes for which it was collected continue; thereafter, your personal data will be destroyed or anonymised from our records and systems, unless we are required to retain it to meet our legal, regulatory, tax or accounting requirements (including under the AMLA).
21.We are committed to ensuring that we, as the Data Controller and the Data Processor (if any), put in place practical measures to protect and store your personal data.
22.Notwithstanding the above, you acknowledge that transmissions over the internet (e.g. emails or data transmissions) are not secure unless encrypted. As your internet communications may be routed through different countries before delivery, we cannot guarantee a risk-free transmission and do not accept responsibility for any unauthorised access, interception or loss of personal data that is beyond our reasonable control.
Use of Artificial Intelligence and Technology-Assisted Tools
23.In the course of assessing applications and providing our services, we may use AI and other technology-assisted tools operated by third-party technology service providers to assist our personnel in tasks such as identity verification, document review and analysis. All outputs generated through such tools are reviewed, verified and approved by our authorised personnel before any decision is communicated to you. No decision is communicated to you on the basis of AI-generated output alone, without prior human review.
24.We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you. The use of AI and technology-assisted tools is limited to assisting our personnel and does not replace human judgement.
25.Personal data processed through AI and technology-assisted tools is subject to the following safeguards:
(a)such data is transmitted to and processed by our technology service providers under binding data processing agreements that impose obligations on data security and confidentiality, and that restrict the use of your personal data to the provision of services to us;
(b)your personal data processed through such tools is retained by our technology service providers only for the duration necessary to complete the specific task, and is deleted thereafter in accordance with our contractual arrangements with such providers; and
(c)in the event of a personal data breach involving your personal data processed through our technology service providers, we will notify you and the relevant authorities in accordance with the requirements of the PDPA and any applicable regulations.
Transfer of Your Personal Data Outside of Malaysia
26.Our information technology storage facilities and servers may be located in jurisdictions outside Malaysia. Accordingly, your personal data may be stored on, disclosed or transferred to servers and entities located outside Malaysia. You hereby consent to us transferring your personal data outside Malaysia for such purposes. We will endeavour to ensure that reasonable measures are taken so that all such third parties outside Malaysia have sufficient technical and organisational security measures or appropriate contractual safeguards in place, including binding data processing agreements where applicable, and do not use your personal data other than for the Purposes and to adequately protect the confidentiality and privacy of your personal data.
Updates to This Privacy Policy
27.We reserve the right to modify, vary, update and/or amend all or any part of this Privacy Policy at any time from time to time, and any such amendment shall form an integral part of this Privacy Policy and will be posted on our Website. By continuing to use our Website or services, or by communicating with us, after any amendment to this Privacy Policy, you are deemed to have agreed to and accepted the amended Privacy Policy.
Prevalence
28.This Privacy Policy is prepared and issued in both the English and Malay languages, in compliance with Section 7(3) of the PDPA. The Bahasa Melayu version is available here.
29.In the event of any inconsistency or conflict between the English version and the Bahasa Melayu version of this Privacy Policy, the English version shall prevail.
Contact Details
30.If you have any questions about this Privacy Policy, or have any further queries, or would like to make a complaint or an access or correction request in respect of your personal data, you may contact us at the contact details below:
Data Protection Officer
GAVO Sdn Bhd
A1-07-08 Arcoris Business Suite, Jalan Kiara, Mont Kiara, 50480 Kuala Lumpur
Telephone: +603 6412 2216 · Email: support@gavofund.com
