Privacy & PDPA Policy

This Personal Data Protection Notice ("Notice") is issued by Hunter Analytix Sdn. Bhd. ("Hunter", "Company", "we", "us", or "our") pursuant to the Personal Data Protection Act 2010 (Malaysia).

This Notice applies to:

• Creditors (banks, leasing companies, financial institutions)
• Repossession agents and recovery agencies
• Vehicle owners / borrowers
• Authorised users of Hunter Repo
• Visitors and system users

By accessing or using the Hunter Repo application ("Platform"), you consent to the collection, processing, storage, use, and disclosure of personal data in accordance with this Notice.

Hunter operates strictly as a technology platform provider and data intermediary facilitating data aggregation, monitoring, analytics, coordination, and reporting.

Hunter:

• Does NOT own vehicle loan accounts
• Does NOT issue loans
• Does NOT determine default status
• Does NOT initiate repossession
• Does NOT act as a licensed repossession agent
• Does NOT provide legal advice
• Does NOT verify legal validity of enforcement actions

All data is submitted by authorised users (creditors and agents).

Hunter shall NOT be liable for:

• Accuracy of submitted data
• Legality of repossession instructions
• Actions taken by creditors or agents
• Disputes between borrowers and financial institutions

• Full name, IC / Passport number
• Contact number, email address
• Company name, business registration number
• Job title / designation, login credentials
• IP address, system access logs

• Full name, IC number
• Contact details, email address
• EPS licence number & expiry
• Assigned organisation

• Full name, contact details, residential address
• Vehicle registration number, make & model, chassis number
• Loan information (arrears, outstanding amount)

• Vehicle plate numbers (captured via ANPR)
• Vehicle images and video captures
• Time, date, and GPS location of detection
• Confidence scores (AI recognition output)
• Movement patterns and detection history

• Device model, OS version, device identifiers (including IMEI where permitted)
• App version, network type, IP address, connection logs
• Real-time GPS location and background location (where enabled)
• Camera, photo gallery, storage, Bluetooth / WiFi access

• Login attempts and session logs
• Device behaviour analytics, tampering / reverse engineering signals
• Root / jailbreak detection status, error logs and crash reports

• Risk scoring profiles, behavioural analytics
• Detection trends, location intelligence patterns
• AI-driven predictions and correlations

Personal data may be obtained from:

• Creditors / financial institutions
• Repossession agents
• Direct user registration
• Device-generated data
• System-generated analytics
• Law enforcement (where applicable)

Hunter does not independently source borrower data outside creditor submissions.

Personal data may be disclosed to:

• Authorised creditors
• Repossession agents
• Internal system administrators
• Cloud and infrastructure providers
• AI and analytics processing systems
• Legal advisors
• Regulators and law enforcement agencies

Hunter does NOT sell personal data.

Hunter implements:

• End-to-end encryption (where applicable)
• Secure API architecture
• Role-based access controls
• Multi-factor authentication
• Device-level security validation
• Continuous monitoring systems
• Audit logs and forensic tracking

Despite these measures, Hunter does not guarantee absolute security and shall not be liable for breaches beyond reasonable control.

Data is retained:

• As required by creditors
• For legal and regulatory obligations
• For dispute resolution
• For audit and system integrity

Hunter may anonymise data for analytics or delete data when no longer required.

Hunter relies entirely on user-submitted data.

Hunter:

• Does NOT verify loan status
• Does NOT validate arrears
• Does NOT confirm legal compliance

Users are responsible for data accuracy.

Data subjects may:

• Request access to personal data
• Request correction of inaccurate data
• Withdraw consent (subject to legal limitations)

To exercise your rights, contact: support@hunterrepo.com

Hunter may charge administrative fees as permitted by law.

Data may be stored or processed outside Malaysia. Hunter ensures reasonable safeguards aligned with PDPA requirements.

To the fullest extent permitted by law, Hunter shall NOT be liable for:

• Actions taken by repossession agents
• Disputes between creditors and borrowers
• Losses from enforcement activities
• Data inaccuracies from users
• System downtime or failures
• Security breaches beyond control
• Indirect or consequential damages

Users agree to indemnify Hunter Analytix Sdn. Bhd. against claims arising from:

• Misuse of data
• Unlawful repossession
• Breach of laws
• Violation of privacy rights
• Improper use of Hunter Repo

Users must:

• Provide lawful and accurate data
• Comply with Malaysian laws
• Obtain necessary consents
• Use data responsibly
• Not misuse the Platform

Users confirm:

• They have authority to submit data
• They have obtained required consents
• They understand Hunter acts as a platform provider only

Hunter Repo may use AI and automated systems. Such outputs:

• Are probabilistic
• Do NOT constitute legal decisions
• Must be independently verified by users

Hunter is not liable for decisions made based on AI outputs.

Hunter reserves the right to amend this Notice at any time. Continued use of Hunter Repo constitutes acceptance of the updated Notice.