To our Customer and Partners:

We know that your personal information is important, and it is at our interest to protect yours. We would like to walk you through an understandable summary of KBL data protection process.

Our goal is your trusted digital wallet partner by ensuring that you have state of the art experience with our platform. To accomplish this noble mission, it requires your trust, and we are always transparent and honest to you to gain this momentum. Your trust is our interest in serving you, and we would like to thank you for that.

Who we are?

Kabaubluy Application (KBL) is your trusted digital wallet partner, a platform that give you state of the art spending and saving experience and help you save more while you spend.
We are a subsidiary of B Scientific Instrument Co., Ltd., and we use Kabaub Luy as the name to the public. We can be reached out via following methods:
Main Office: #178E0E1, Street 1972, Phnom Penh Thmey, Sen Sok 120801 , Cambodia Phone: (+855) 23 902 088 Email: kbl@bsi.com.kh While visiting our website, singing up for an account, placing orders, starting any transaction, you agree to this privacy policy. This privacy documents how we process your personal data, for what purposes and by what means. While we are required by law to provide you with all the following information, we do so primarily out of the belief that a partnership should always be honest. We are responsible that all our processing activities are in accordance with legal requirements but also you may reasonably expect these processing of your personal data (link to "legitimate and ethical interests"). We will continue to be your point of contact if you have any questions about data protection. If you have any questions about data protection at KBL App, you can also contact our data protection officer at any time by sending an email to kbl@bsi.com.kh

Privacy is your right, and you have the choice.

As a customer and a user of our platform, you have the choice on limiting the information you would like to share with us. Yet, we need some information for the fulfillment of our contract. However, this does not always require all the data which you can make available to us. You can take the following steps to disclose less information about yourself: Cookies: You can install additional add-ons in your browser that block unnecessary cookies. By doing so, you will not see any interest-based advertisements. Advertising: If you do not want to receive any promotional martials from us when registering providing us an email, you can unsubscribe at any time. In this case, we will not be able to send you any cool offers. No data sharing: If you don't want to share any information with us at all, we may not be able to let you experience and convince you how great our products are.

You can also make use of the following rights at any time:

Right to access: You are informed about the data we store about you and how we process it. Right to rectification: We will correct your data when receiving your notification of the incorrectness. Right to erasure: We will delete the data we have stored about you upon your request. Right to reject processing your data: You can revoke your consent at any time or object to the further processing of your data. This also includes objecting to our processing, which we process without your consent but based on our legitimate and ethical interest. This applies, for example, to direct marketing. If you do not agree with one of our processing purposes based on our legitimate and ethical interest or wish to object to it, you may object to the processing at any time on grounds. Please write an email to kbl@bsi.kh.com. In this case we will review the processing activity again and either stop processing your data for this purpose or explain to you our reasons worth protecting and why we will continue with the processing. Right of complaint: If you believe that we have done something wrong with your personal data or your rights, you can complain to the appropriate supervisory authority at any time. To exercise your rights, you can contact kbl@bsi.com.kh at any time.

What data we process

In the following description of our processing activities, we refer in each case to categories of personal data. A category includes several personal data, which are usually processed together for the purposes. Personal data is information that can identify you or even make you identifiable. We generally process the following categories of personal data for the following reasons:
1. Contact Information: Name, address, telephone number, email address. Reason: If you contact us, we collect this data because we need to know who we are talking to and what we have been talking about so that we can help you with your reason for contacting us.
2. Profile data (master data): Name, email address (optional), password, telephone number, interests, demographic data (age, delivery address) Reason: This data is your master data, which we absolutely need for our services. Without an email address / telephone number and a password, you cannot create an account. Together with your name, this is your master data. We need your age to ensure that you are not a minor.
3. Device information and access data: Device ID, device identification, operating system and corresponding version, time of access, configuration settings, information on Internet connection (IP address) Reason: With each access this information is stored by us for technical reasons. We also use parts of this information to detect suspicious behaviour at an early stage and to prevent the damage.
4. In-app Purchase information: Purchase history, selected restaurants, invoices, order ID, comments on orders, information on payment method, successful orders, and cancelled orders. Reason: When you place an order via in-app purchase function, this information will be added to your transactions. You can view all this information under the transaction at any time. The information should give you an overview of your own interests and previous orders. We will also use the same information to improve our services. In addition, we will remove this information when you request a deletion or when your profile becomes inactive to continue to use this information in an anonymized form to optimize our services.
5. Communication data: Name, email address, telephone number, device ID Reason: For any in-app push notification from us, we need certain information to send you the messages. We believe in a more personalised message to address you with your name or family name instead of the generic one like "Hello Sir/Madam. This category of personal information is also used by us to contact you, for example, if you can’t redeem the reward item delivered and we want to offer you an alternative instead.
6. Transaction information: Account name, account number, transaction type, amount, and datetime. Reason: We need this information to track and calculate and record the transactions. In the case of errors or suspicious, it is easy for retrieval for yourself and from our side. ACCOUNT CREATION & ADMINISTRATION OF YOUR PROFILE To offer you our services, the processing of your personal data is essential. Much of this data you transmit to us and other parts of the data we collect automatically when using our platforms. Nevertheless, we endeavour to keep the amount of data as small as possible. You can help us by only sharing necessary data with us that we need to fulfill our contractual obligations.
7. Account Creation: When creating a customer account you will be asked to enter your master data. This is necessary, as we cannot create a customer profile without this data. Your telephone number are particularly important, as we can use this information to identify you in our system the next time you want to log in again. Furthermore, we would like to ask you to choose your password carefully. Do not use the same password on multiple websites. Your password should also be at least 8 characters long, at least one lowercase letter, one uppercase letter, one special character (!?#,%& etc.) and one digit. Please don’t share neither your log it details to somebody else. Categories of personal data: Profile data (master data). Device information and access data. Legal basis: Performance of contract
8. Login: If you already have an existing customer account, you will need to enter your telephone numbers and password to log in. If we detect irregularities during registration, such as entering the wrong password several times, we will take appropriate measures to prevent damage to you and us. Categories of personal data: Profile data, location data, Order information, Device information and access data, Order information, Communication data, Payment information. Legal basis: Performance of contract
9. ORDER/TRANSACTION PROCESSING Once you have successfully registered and decided to start your transaction and/or your order, we will store this information in your profile and process it in further processes so that you can submit your order via our platform. When you submit your order, your personal data is transferred to our backend where it is transferred to other systems for further processing. Categories of personal data: Profile data (master data), Device information and access data, Order information. Legal basis: Legitimate interest The legitimate interest is to provide you with a better ordering experience where you can conveniently continue your order with browsers or apps that are accidentally closed.
10. TOP UP METHODS To refill the credit points in the app and making it even more convenient for you, we offer two options for the top up method. We record this information in your transaction history to track whether your payment is successful. Categories of personal data: Payment data Legal basis: Consent
11. ADVERTISING AND MARKETING Online Promotional Materials If you registered for an account using the email address in addition to the telephone number given, when making any transaction on our platform, we reserve the right to send you regular offers of similar goods, rewards, or services to you from your range by email. We use different information from your order history and reward items claimed. This is a profiling process in which we automatically process your data. The specific customer segmentation can have a legal effect on you or can have a significant effect on you in other ways if you receive certain newsletters and are not included in other campaigns. If any automation in processing your information leads to a negative result for you and you do not agree with this, you can contact us at kbl@bsi.com.kh . In this case, we will individually assess the circumstances of your case. Categories of personal data: Contact Information, Location data, Order information. Legal basis: Data processing in this respect takes place solely based on our legitimate interest in personalised direct marketing. If you have initially objected to the use of your email address for this purpose, we will not send you an email for marketing purposes. You are entitled to object to the use of your email address for the advertising purposes at any time with effect for the future by notifying the person responsible named at the beginning. Upon receipt of your objection, the use of your email address for advertising purposes will be discontinued immediately.
12. UI/UX Survey (User Experience Surveys) We seek to constantly improve our services, and we value your constructive feedback. Therefore, we will occasionally send you the customer surveys and ask you to give us your opinion. You can unsubscribe at any time by clicking "unsubscribe" button in our email, and we will not contact you again. We always develop new products and try to adapt our services to the wishes of our customers. To measure the effectiveness of these changes, we regularly offer interviews with our User Experience team. In these interviews we record your usage behaviour and ask you for possible optimisation possibilities. Participation in the interviews requires your consent. If you have already given your consent and would like to revoke it for the future, you can do so at any time by sending an email to kbl@bsi.com.kh. In this case we will exclude you from participating in our interviews and you will not receive any further invitations for them. Categories of personal data: Communication data Legal basis: Legitimate and ethical interest. Our legitimate interest is the purpose described above.
13. Deals and notifications We have a strong interest in informing you about new restaurants or deals when using our app. We are always working to give you an amazing customer experience. To achieve this, we work with the store to offer you very good deals. To inform you about these deals, we send you in our Apps in-app-notification or push-notification. It is imperative that you have activated this in your end devices. Categories of personal data: Contact Information, Order information. Legal basis: Consent
14. Online marketing Our service is based largely on convincing potential customers that we offer an amazing customer experience and that every visit to our platform is worthwhile. In order to reach as many potential customers as possible, we are very active in the field of online marketing. It is just as important to win the trust of potential customers and to strengthen the trust of our existing customers. Therefore, we would like to present you our processes as transparent as possible. Targeting In principle, targeting means the switching and fading in of advertising banners on websites that are tailored to specific target groups. The aim is to display the most attractive banners as individually as possible for the user and potential customer. Firstly, we define a target group and secondly, we commission our service providers to show our advertising to the defined target group. We do not process any personal data, as these are initially made anonymous. To better define the target group, we segment customer types and place different ads on different portals. Retargeting As soon as you have visited our website and, for example, have already placed an order in your shopping cart, we store this information in cookies. If you continue to surf other websites, our advertising partners will remind you on our behalf that you have not yet completed your order. We don't want you to miss out on our amazing customer experience. You can disable retargeting by installing appropriate add-ons for your browser. Furthermore, you can and should also regularly delete the cookies stored in the browser you are using. Categories of personal data: Contact Information Legal basis: Legitimate interest. Our legitimate interest is the purpose described above.
15. Reward Points Programs We want to reward our customers' loyalty with attractive deals and points. For this reason, we offer our customers the opportunity to earn the reward points every time they make the purchases. You will receive the reward points half of the actual amount you spend per the transaction. For instance, you may make a purchase of ten dollars, you will receive 5 reward points. Categories of personal data: Contact Information Legal basis: Consent
16. CUSTOMER RELATIONSHIP MANAGEMENT Your requests Your satisfaction is our biggest goal. Therefore, we are very keen to be available for all your questions and to answer them. To be able to answer these questions and understand the overall problem, we store the conversation content in our Customer Relationship Management System when you contact us. The content of the information we store depends on the information you provide to us as part of our communications. Categories of personal data: Contact Information, Order information. Legal basis: Performance of contract
17. CALL CENTRE If you contact us by phone, we store the conversation with your consent for quality assurance purposes. In individual cases, we also use the recordings for Quality improvement in customer service, i.e. for training purposes (coaching) with our employees. The content of the information we store depends on the information you provide to us as part of our communications. The stored telephone calls are deleted after 90 days at the latest or if the purpose of the storage, i.e. the quality check, is fulfilled earlier. Categories of personal data: Contact Information, Order information. Legal basis: Consent
18. FRAUD PREVENTION AND SECURITY OF OUR PLATFORM To protect our customers and our platform from possible attacks, we continuously monitor the activities on our website for all visitors. To this end, we use various technical measures to ensure that suspicious behavior patterns are detected at an early stage and prevented in good time. To achieve this goal, several monitoring mechanisms run in parallel and prevent potential attackers from accessing our website at all. The decision-making process is automated and can have a legal effect on the person concerned or affect them in a similar way. If automated decision-making leads to a negative result for you and you do not agree with this, you can contact us at kbl@bsi.com.kh. In this case, we will individually assess the circumstances of your case. Categories of personal data: Device information and access data, Contact information, Payment and transaction information, Order information, Voucher information. Legal basis: Consent
19. MERGER & ACQUISITIONS, CHANGE OF OWNERSHIP We would also like to inform you that in the event of a merger with or acquisition by another company, we will disclose information to that company. Of course, we will require the company to comply with the legal data protection regulations. Categories of personal data: Contact information, Delivery information, Location data, Profile data (master data), Device information and access data, Order information, Communication data, Payment information,
20. Voucher Information Legal basis: Legitimate interest, Our legitimate interest is the purpose described above. VOUCHERS We often offer vouchers for our platforms. The reasons can be vary. The purpose of these vouchers provides our loyal customers with rewards on top of the reward items, discounts, and promotion and to encourage them to continue to become our loyal customers. To be able to check the number, the value, and the frequency of use of the vouchers, but also to avoid misuse of these vouchers, we collect various personal data. Categories of personal data: Profile data (master data), Voucher information Legal basis: Legitimate interest, Our legitimate interest is the purpose described above.
21. PROSECUTING AUTHORITIES AND LEGAL PROCEEDINGS Unfortunately, it can happen that a few of our customers and service providers do not behave fairly and want to harm us. In these cases, we are not only obliged to hand over personal data due to legal obligations, but it is also in our interest to prevent damage and to enforce our claims and to reject unjustified claims. How long we store your data We generally delete your data after the purpose has been fulfilled. The exact deletion rules are defined in our regional deletion concepts. Different deletion rules apply depending on the purpose of the processing. Within our deletion concepts we have defined various data classes and assigned rule deletion periods to them. The data collected is marked with a deletion rule. When the retention period is met, the stored data will be deleted accordingly. We will delete your personal data either if you wish and let us know or if your account is inactive for three years, we will also delete your account. Before this happens, you will receive a separate notification from us to the email address registered in your user account. In addition to the deletion rules defined by us, there are other legal retention periods which we must also observe. For example, tax data must be kept for a period of between six and ten years or even longer in some cases. These special retention periods vary according to local legal requirements. Therefore, despite your request for deletion of your data, we may still have to store some of the stored data due to legal regulations. In this case, however, we will restrict data from further processing. Furthermore, we will continue to store your data if we have a right to do so in accordance with applicable local laws. This applies in particular if we need your personal data for the establishment, exercise or defence of legal claims. Right of modification We reserve the right to change this data protection declaration in compliance with the statutory provisions. We will inform you of any significant changes, such as changes of purpose or new purposes of processing.