Privacy Policy

Privacy Policy

Effective date: 30 June 2026
Last updated: 29 October 2026

1. Introduction

This Privacy Policy explains how iStamp (“we”, “us”, “our”) collects, uses, discloses, stores, and protects personal data when you use our website, applications, and services (the “Service”).

This Policy applies to:

• Merchants (business users who register and operate loyalty programs)
• Merchant Staff (users invited by Merchants)
• Customers (individuals who join a Merchant’s stamp program), whether at the counter, on the web, or in the iStamp App for iOS and Android, with or without a Customer Account
• Visitors to our marketing site and Explore directory

Operators:

• Thinking Studio (Malaysia) Sdn. Bhd. (Malaysia) — primary operator for Malaysian Merchants
• Thinking Studio LLC (State of Delaware, United States) — for non-Malaysia Merchants where applicable

Contact: privacy@thinkingstudio.my

2. Important roles — who is responsible for what?

2.1 iStamp as platform provider

We process data to provide, secure, and improve the Service, bill Merchants, and comply with law.

2.2 Merchants as program operators

When a Customer joins your stamp program, you decide what rewards to offer and how the program runs. For Customer personal data collected for your loyalty program, you are typically the data user / controller under Malaysia’s Personal Data Protection Act 2010 (PDPA) (or equivalent law in your country), and iStamp acts as a service provider / processor processing that data on your instructions via the platform.

Merchants must:

• Provide Customers with appropriate privacy notice (your program terms may reference data use)
• Respond to Customer rights requests where you are controller
• Only collect data you need and use it lawfully
• Not upload unlawful or excessive personal data into the Service

2.3 Customers

Customers interact with Merchants through iStamp tools. Customers may contact the Merchant for program-specific questions, and iStamp for platform/security issues.

If you create a Customer Account in the iStamp App, iStamp is the controller for your account data (login, profile, notification settings, and the link between your account and your cards). Each Merchant remains the controller for the stamp records of its own program.

3. Personal data we collect

3.1 Merchant and Staff account data

3.2 Customer data (via Merchant programs)

A Customer Account is optional. You can collect stamps as a walk-in Customer without an email or password.

3.2A Customer Account data (iStamp App)

What the app does not do: the iStamp App does not include advertising, cross-app tracking, or third-party analytics SDKs, and does not access your contacts, photos, or microphone. Location is used only while the app is open and only after you grant permission.

3.3 Merchant-uploaded content

Promo banners, program terms, marketing copy, and CRM notes may contain personal data if Merchants include it. Merchants are responsible for what they upload.

3.4 Communications

Support emails, feedback, and optional WA Follow-up / WhatsApp message content initiated by Merchants (messages are typically composed and sent by Merchants outside or via linked flows — we store templates and segment metadata as configured).

3.5 Cookies and similar technologies

We use cookies and local storage on the web, and secure on-device storage in the iStamp App, for:

• Session authentication (Merchants, Staff, and Customer Accounts)
• Language preference (locale cookie on web; stored setting in the app)
• Security and fraud prevention
• Cached data for faster loading in the app

See Section 10 and our separate Cookies Policy.

4. How we use personal data

We use personal data to:

1. Provide the Service — accounts, stamp programs, QR, scan/redemption, CRM, My cards, linking walk-in cards, Explore and nearby shops, and promo notifications you opt into
2. Secure the Service — dynamic QR, cooldowns, access control, audit logs (staff_id on transactions)
3. Process payments — subscriptions via Billplz (Malaysia) and/or Paddle (international)
4. Communicate — service notices, billing, security alerts, product updates
5. Improve the Service — aggregated analytics, debugging, feature development
6. Comply with law — respond to lawful requests, enforce Terms
7. Protect rights — fraud investigation, dispute handling

Legal bases (where applicable):

• Contract — to perform our agreement with Merchants, and with Customers who create a Customer Account
• Legitimate interests — security, improvement, fraud prevention (balanced against rights)
• Consent — where required (e.g. device location, promo push notifications, optional marketing if offered). You can withdraw consent in the app or in your device settings
• Legal obligation — tax, regulatory, court orders

5. How we share personal data

We do not sell personal data.

We may share data with:

Merchant Staff with appropriate roles can view Customer profiles, stamp history, and notes within that Merchant’s account only (enforced by Row Level Security).

6. International transfers

6.1 Our primary database region is Singapore (ap-southeast-1) via Supabase, which may involve transfer of personal data outside Malaysia or your country.

6.2 We implement appropriate safeguards consistent with applicable law (including PDPA requirements for cross-border transfers where relevant).

6.3 Payment processors may process data in their own regions per their policies.

7. Data retention

We may anonymise or aggregate data for analytics and retain anonymised data longer.

Merchants may export Customer data (on eligible plans) before account closure. After termination, deletion timelines apply per contract and law.

8. Security

We implement technical and organisational measures including:

• Encryption in transit (HTTPS/TLS)
• Row Level Security (RLS) on database tables — Merchants isolated from each other
• Dynamic QR with short expiry and HMAC signatures
• Role-based access for Staff
• Audit fields on stamp transactions (staff_id, timestamps)
• Hashed passwords for Merchant and Customer accounts (via Supabase Auth)
• Secure device storage — the iStamp App keeps your sign-in session in the iOS Keychain or Android Keystore

No system is 100% secure. Report suspected incidents to privacy@thinkingstudio.my promptly.

9. Your rights

9.1 Merchants and Staff

Depending on jurisdiction, you may have rights to access, correct, delete, or restrict processing of your personal data, and to object to certain processing. Contact privacy@thinkingstudio.my. We may verify identity before responding.

9.2 Customers

Contact your Merchant first for stamp balance, program terms, and correction of name/phone in their CRM.

For platform issues (e.g. lost access link, security concern), contact privacy@thinkingstudio.my with Merchant name and phone used at registration. We will coordinate with the Merchant where appropriate.

Deleting your Customer Account: in the iStamp App, go to Account → Delete account. This permanently deletes your login, profile, and push notification settings, and unlinks your cards from your account. It happens immediately and cannot be undone.

• Your stamp records stay with each Merchant as walk-in cards, because they are part of that Merchant’s loyalty records. You can link them again later with a new account.
• To have a Merchant’s stamp record erased as well, ask that Merchant, or email privacy@thinkingstudio.my and we will pass the request on.
• If your login also owns or staffs a Merchant, it cannot be deleted in the app, because that would close the shop. Contact admin.thinkingstudio@gmail.com.
• If you signed in with Apple, you can also remove iStamp from Settings → Apple ID → Sign in with Apple on your device.

9.3 Malaysia — PDPA

Malaysian data subjects may have rights under the PDPA 2010, including access and correction. Submit requests to privacy@thinkingstudio.my. We respond within timeframes required by law.

9.4 Withdrawal of consent

Where processing is consent-based, withdrawal may affect ability to use certain features.

10. Cookies and tracking

You can control cookies via browser settings. Blocking essential cookies may break login. In the app, signing out clears your session and cached data.

We do not use third-party advertising cookies or cross-app tracking anywhere in the Service. Full details are in our Cookies Policy at https://istamp.io/legal/cookies.

11. Children

The Service is not directed at children under 13 (or under 18 for Merchant accounts). We do not knowingly collect data from children. If you believe we have, contact privacy@thinkingstudio.my for deletion.

12. Merchant obligations summary

If you are a Merchant, you agree to:

• Have a lawful basis to collect Customer phone/name
• Not use exported lists for spam without consent
• Configure retention-appropriate notes in CRM
• Notify us at privacy@thinkingstudio.my of any personal data breach involving the Service affecting your Customers

13. Changes to this Policy

We may update this Privacy Policy. We will post the new version with an updated effective date and, for material changes, provide notice via email or in-app where appropriate.

14. Contact & data protection enquiries

This Privacy Policy should be read together with our Terms of Service, Cookies Policy, and Refund Policy.