TMC Thering Mobile Communication
Privacy Policy

1. Introduction

This Privacy Policy is issued jointly by TMC — Thering Mobile Communication (SSM: NS0160370-K) and BYCOMM — By Communication Services(together, "TMC", "we", "us", or "our"). We operate a phone installment retail and financing introduction service in Malaysia, headquartered in Nilai, Negeri Sembilan. This policy explains what personal data we collect from you, how we use it, who we share it with, and your rights under the Malaysian Personal Data Protection Act 2010 ("PDPA"). It applies to everyone who interacts with us through this website, WhatsApp Business, Instagram Messaging (Meta Direct Messages), or at our physical store.

2. Information We Collect

When you enquire about or apply for a phone installment plan, we may collect:

• Identity information: full legal name, Malaysian NRIC / IC number, date of birth, nationality, photograph of your IC (front and back).
• Contact information: mobile phone number (including your WhatsApp / Instagram handle), email address, residential address, mailing address.
• Employment & financial information: employer name, job title, employment start date, monthly income shown on payslips, bank statement (only when required by the lender), existing installment or credit obligations you disclose.
• Documents you upload or send: IC photos, payslips, bank statements, utility bills, SSM certificates (self-employed), and any other supporting documents shared via WhatsApp, Instagram, or website forms.
• Message content: the text, images, and files you send us in our WhatsApp Business chat, Instagram DM conversations, and website contact forms.
• Product interest: the phone model, storage, colour, and installment tenure you are considering.
• Website usage data: anonymous analytics information such as page views, referring URL, device type, and approximate location (country / region only), collected through Google Analytics 4 and Meta Pixel + Conversions API.

3. How We Collect Your Information

We collect information only when you voluntarily provide it, through:

• WhatsApp Business API — when you message our official business number and share documents or replies with our sales team.
• Instagram Messaging (Meta Direct Messages) — when you DM our official Instagram business account and share your enquiry with our sales team.
• Our website (theringpro.com) — through public product pages, the eligibility quiz, callback request form, and contact page.
• In person — when you walk into our shop at PT 5732, Jalan TS 2/1D, Taman Semarak 2, 71800 Nilai, Negeri Sembilan.
• Ads & tracking — anonymous ad-click and website analytics through Meta Pixel, Meta Conversions API, and Google Analytics 4.

We do not purchase your data from third-party lead brokers, and we do not scrape your contact information from unrelated public sources.

4. How We Use Your Information

Your personal data is used only for the purposes listed below:

1. To assess your eligibility for a phone installment plan (age, employment stability, disclosed income).
2. To submit and manage your loan application with JCL Credit Leasing, the licensed credit provider that issues the installment loan.
3. To arrange delivery of your device via authorised couriers.
4. To communicate with you about your enquiry, application status, delivery, and after-sales support.
5. To follow up when your application requires additional documents or clarification.
6. To comply with legal obligations, including record-keeping under Malaysian tax and audit law.
7. To improve our website and marketing through anonymous analytics.

5. How We Share Your Information

We share your personal data only with the parties listed below, and only to the extent necessary for the purpose of sharing:

• JCL Credit Leasing— the licensed credit provider that issues the installment loan. Your identity documents, income proof, and application form are shared with JCL so they can approve, issue, and administer the loan. JCL is a credit company licensed under Malaysia's Moneylenders Act 1951 and processes your data under its own privacy commitments.
• Meta Platforms Ireland Limited(WhatsApp Business, Instagram Messaging) — the messages you send us pass through Meta's infrastructure. Meta's handling of that data is governed by Meta's own Privacy Policy, which we cannot vary. See Meta's Privacy Policy for details.
• Delivery couriers (e.g. Gdex) — your name, delivery address, and phone number, solely for the purpose of delivering your device.
• Payment processors and banks — for processing installment payments and any refunds.
• Government authorities and regulators — where we are legally required to disclose data (e.g. court order, tax investigation, Bank Negara Malaysia enquiry, PDPA regulator).
• Professional advisors — accountants, auditors, and lawyers, bound by confidentiality.

We do NOT sell your personal data. We do NOT rent or trade your contact list. We do NOT share your data with third parties for their own marketing.

6. Data Retention

We retain your personal data for the following periods:

• Active customers — for the duration of your installment agreement, and for seven (7) years after your final payment, as required by Malaysian tax and audit legislation.
• Applications that were rejected or withdrawn — for twelve (12) months from the decision date, after which we delete or anonymise the record.
• Website analytics— retained per Google Analytics and Meta's default policies (typically up to fourteen months for user-level data).
• WhatsApp and Instagram message threads — retained on our systems for up to twenty-four (24) months for customer-service and audit purposes, then deleted unless still required for an active case.

7. Your Rights Under Malaysia's PDPA

Under the Personal Data Protection Act 2010 you have the right to:

• Access the personal data we hold about you.
• Correct any inaccurate or outdated information.
• Withdraw your consent to us processing your data. Withdrawing consent may end your active installment application or agreement.
• Request deletion of your data, subject to the retention periods required by law (see Section 6).
• Complain to the Malaysian Department of Personal Data Protection (Jabatan Perlindungan Data Peribadi, JPDP) if you believe your rights have been violated.

To exercise any of these rights, contact us using the details in Section 12. We will acknowledge your request within seven (7) working days and respond substantively within twenty-one (21) working days.

8. Data Security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure:

• Documents and structured customer records are stored in encrypted, access-controlled cloud databases (Supabase) hosted in a secure Southeast Asian data centre region.
• All web traffic to theringpro.com is served over TLS 1.2+ (HTTPS).
• Access to customer data is restricted to authorised TMC and BYCOMM staff on a need-to-know basis and is logged.
• Our admin systems require strong passwords and rate-limit failed login attempts.
• WhatsApp and Instagram DM conversations use the encryption provided by Meta.
• We do not store customer documents on personal devices, unmanaged USB drives, or unsecured consumer cloud drives.

No system is completely secure, and we cannot guarantee absolute security. If we become aware of a data breach that materially affects you, we will notify you and the PDPA regulator as required by law.

9. Third-Party Platforms — Meta (WhatsApp & Instagram)

We use Meta's business tools to communicate with you and measure our advertising:

• WhatsApp Business API — for two-way messaging between you and our sales team.
• Instagram Messaging (Meta Direct Messages) — for two-way messaging when you contact our Instagram account.
• Meta Pixel and Conversions API — to measure which of our advertisements are effective. These tools collect anonymous event data (page views, button clicks, conversions); they do not receive your name, IC, or payslip.

When you interact with us on WhatsApp or Instagram, Meta's own terms and privacy policy also apply to your data. We cannot vary Meta's policies; please review them here:

• Meta Privacy Policy
• WhatsApp Business Policy

10. Children

Our services and installment plans are intended for individuals aged eighteen (18) years and above. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, please contact us immediately using Section 12 and we will delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or the law. The current version is always published at theringpro.com/privacy-policy with the effective date at the top. Material changes will be highlighted for at least thirty (30) days. Continuing to use our services after a change takes effect indicates your acceptance of the updated policy.

12. Contact Us

For questions about this Privacy Policy, to exercise your PDPA rights, or to raise a privacy complaint, please contact:

We aim to acknowledge every privacy enquiry within seven (7) working days and respond substantively within twenty-one (21) working days, as required by the PDPA.

Ringkasan (Bahasa Malaysia)

Terjemahan ringkas — versi Bahasa Inggeris di atas adalah versi rasmi.

TMC (Thering Mobile Communication, SSM: NS0160370-K) dan BYCOMM menghormati privasi anda. Kami mengumpul maklumat peribadi anda — seperti nama, IC, nombor telefon, alamat, slip gaji, dan dokumen-dokumen yang anda kongsikan melalui WhatsApp Business, Instagram DM, laman web kami, atau kedai kami — semata-mata untuk memproses permohonan ansuran telefon anda dan menghantar telefon anda.

Kami berkongsi data anda hanya dengan rakan pembiaya berdaftar kami JCL Credit Leasing, syarikat penghantaran (contoh: Gdex), pihak berkuasa jika dikehendaki oleh undang-undang, dan platform Meta (WhatsApp / Instagram) untuk membolehkan komunikasi. Kami tidak menjual data anda atau berkongsi dengan pihak ketiga untuk pemasaran mereka.

Di bawah Akta Perlindungan Data Peribadi 2010 (PDPA), anda berhak akses, membetulkan, memadamkan data anda dan menarik balik persetujuan. Untuk sebarang pertanyaan atau permintaan, sila hubungi kami di jcl.thering.mobile@gmail.com atau WhatsApp +60178582722.