Privacy Policy
How Untunglah Pro collects, uses and protects your personal data
In plain language: Your accounting data belongs to you. Your live data is kept in a private database in Singapore, we use it only to run Untunglah Pro for you, and we never sell it. If you use Untung, our assistant, your question and the details needed to answer it are sent to Google to write the answer. You can export everything at any time. When you delete a company it is deleted immediately from the live service and we cannot recover it for you. We keep encrypted backups of the whole Service for 35 days for our own disaster recovery only, and we do not use them to recover an individual company's data.
1. Introduction and scope
ES Dot Net Enterprise ("we", "us", "our") process personal data in line with the Personal Data Protection Act 2010 of Malaysia (PDPA 2010).
This policy explains what we collect, why, who helps us run the service, how long we keep it, and the choices you have when you use Untunglah Pro (the "Service") at pro.untunglah.com.my. It applies to people who sign in to the Service. Section 2 explains who is responsible for the personal data of other people that appears in a business's accounting records.
2. Who is responsible for your data
ES Dot Net Enterprise (SSM 200303011713 (001391879-W)), 2-01-37, D'Alamanda, Pudu Impian IV, Jalan Pudu Impian, Taman Pudu Ulu, 56100 Kuala Lumpur, Malaysia. Email: hello@untunglah.com.my.
We are the data controller for the personal data of the people who sign in and for billing: your account data, your sign-in and activity records, technical data, and the billing data of the company that pays for the Service.
For the records a business keeps in the Service about its own customers, suppliers and staff (their names, contact details, ID numbers, bank account numbers and so on), the business that owns the company is the data controller and Untunglah is its data processor. We process those records only on the business's instructions, to provide the Service. If you are a person whose details appear in a business's records, please contact that business first about your data; we will help the business respond to you.
3. What we collect
| Category | Examples | Why |
|---|---|---|
| Account data | Name, email address and profile photo from your Google account | Sign-in and showing who did what |
| Company data | Company name, SSM number, TIN, SST number, address, bank account details, logo, taxpayer QR image | Setting up your company, invoices and e-Invois |
| Accounting data | Journals, invoices, bills, receipts, payments, stock, bank statements and the names and contact details of your customers and suppliers, including customer ID numbers (such as NRIC or passport numbers, where you enter them for e-invoicing) and payee bank account numbers | The core of the Service |
| Invitation data | Email addresses of people you invite to a company | Sending the invitation and giving access |
| Uploaded files | Bank statement files, attachments, payment batch files, company logo | Storing the files you ask us to keep |
| Activity records | Audit log of changes (who, what, when), notifications, comments | Accountability and security |
| Untung chats and usage | Your questions to Untung, its answers and the figures shown with them; the number of questions you ask and the amount of AI processing used each day | Answering your questions, enforcing daily limits and controlling costs |
| Support messages | Your email address, company name and the message you send through Contact support or by email | Answering your question and keeping a record of the help we gave |
| Technical data | IP address, browser type and request logs | Security, troubleshooting and preventing abuse |
| Billing data | Plan, billing status and payment references | Charging for paid plans |
Supplying the account and company data above is necessary to use the Service: without it we cannot create your account or company. Everything else (for example optional contact details, logos, or ID numbers on customer records) is up to you; if you do not supply it, the related feature, such as e-invoicing a particular customer, may not work.
We do not intentionally collect sensitive personal data such as health, religion or biometric data. Please do not put such data in free-text fields, uploads or Untung chats, and do not type other people's ID numbers, bank details or passwords into Untung.
4. How we collect it
- From you, when you create a company, enter transactions, import files, invite colleagues or ask Untung a question.
- From Google, when you sign in: your name, email address and profile photo.
- Automatically, through request logs and the audit log, when you use the Service.
- From LHDN MyInvois: when you create a company or look up a TIN, we query LHDN using our own credentials. If you connect your own MyInvois account, we also receive the validation status and identifiers LHDN returns for documents you submit.
5. How we use it
- To provide, secure and support the Service, including posting entries, producing reports and PDFs, and sending the emails you ask for (invitations, statements, reminders, invoices to your customers).
- To manage your account, company membership and plan.
- To submit e-invoices to LHDN MyInvois when you have connected your own MyInvois account and choose to submit.
- To process payments for paid plans.
- To answer your questions in Untung, our built-in assistant, when you choose to use it. Untung's answers are written by an AI model (Google Gemini). To answer, Untung reads your books using your own permissions and sends Google your question, recent messages in that chat, and the details from your books needed to answer it (see section 6). Untung gives general information from your records; it is not accounting, tax or legal advice.
- To read bills and receipts you scan, when you choose to use Scan bills. The photo or PDF you upload is sent to an AI model (Google Gemini), which reads the supplier, document number, date and amounts so that we can prepare a draft bill for you to check. Nothing is posted until you save the draft and post it yourself. The AI can misread a document, so always check it against the original.
- To detect and prevent fraud, abuse and unauthorised access, and to meet our legal obligations.
We do not sell your data, we do not use it for advertising, and we do not use your individual accounting data to build profiles or train models.
6. Who else handles your data
We use the following providers to run the Service. They process data on our behalf to provide it, and some also keep limited records for their own security, abuse-prevention and legal duties, as noted below.
| Provider | What for | Data involved | Location |
|---|---|---|---|
| Supabase | Database, sign-in and file storage | All data in your account | Singapore |
| Google Cloud (Cloud Run, Cloud Logging) | Hosting the application; application logs | Cloud Run: data in transit and in memory while a page or file is served, not stored there. Logs: request logs (IP address, browser type, user and company identifiers); not designed to hold accounting data | Application: Singapore. Logs are stored by Google Cloud Logging and may be held outside Singapore. |
| Sign-in with your Google account | Name, email address, profile photo | Global | |
| Resend | Sending email (invitations, statements, reminders, notices, invoices) | Recipient address, email content and attached PDFs, e.g. invoices to your customers | Region as configured in our Resend account; may be outside Malaysia (for example the United States). |
| Google (Gemini API) | Answering your questions in Untung, only when you use it | Your question, recent messages in that chat, your company name, and the details from your books needed to answer it, such as figures, document numbers, customer and supplier names and, for questions about who did what, colleagues' email addresses. Sent under Google's paid-service terms: Google does not use it to improve its products, but keeps it for up to 55 days to detect abuse and for legal reasons, during which authorised Google staff may review it. | Google's global infrastructure; may be outside Malaysia, including the United States. |
| Google (Gemini API) | Reading bills and receipts you upload in Scan bills, only when you use it | The uploaded photo or PDF itself, and nothing else from your books. Sent under Google's paid-service terms: Google does not use it to improve its products, but keeps it for up to 55 days to detect abuse and for legal reasons, during which authorised Google staff may review it. | Google's global infrastructure; may be outside Malaysia, including the United States. |
| LHDN MyInvois | TIN lookups and company checks using our credentials; e-invoice submission only when you connect your own MyInvois account | TIN lookups: the identifiers you enter. Submission: the e-invoice documents you choose to submit, in your name with your credentials | Malaysia |
| Curlec (when paid plans are available) | Payments for paid plans | Billing contact and payment references; card details go to Curlec, not to us | Location as described in Curlec's own privacy policy. |
We may disclose personal data where the law, a court or a regulator requires it. We will tell you first where we are allowed to.
7. Storage and security
Your live data is stored in Singapore. Encrypted backups of the database and uploaded files are kept on a secured computer controlled by ES Dot Net in Malaysia, and we hold the encryption key. Some of the providers above process data outside Malaysia, including in the United States. By using the Service you consent to your personal data being transferred to, stored and processed in those places for the purposes in this policy.
- Connections are encrypted with TLS.
- Each company's data is separated at the database level, so users only see companies they belong to; inside a company, access follows the permissions the owner sets.
- Files are kept in a private storage bucket and are served only through short-lived signed links.
- Sensitive credentials such as your LHDN client secret are stored encrypted.
- Access by our staff to production data is limited to what is needed to run and support the Service.
- Application logs are kept for about 30 days and are not designed to hold accounting data.
If a personal data breach affects you, we will tell the owner of the affected company without undue delay, and we will notify the Personal Data Protection Commissioner and affected individuals where the law requires. For records the business controls, the business decides, with our help, whether individuals must be told.
8. Retention, deletion and your own copies
We keep your data while your company is active in Untunglah Pro. If no user of a company has signed in for 12 consecutive months, we may delete the company and its data after emailing the company owner at least 30 days beforehand; a company with a paid plan still within its paid period is not treated as inactive. This deletion works like an owner deleting the company (see below).
You are responsible for keeping your own copy of your data: export it regularly from Settings > Company > Export all company data. When a company owner deletes a company, it is deleted immediately from the live service. We cannot and are not obliged to recover it.
- Deletion removes the company's records, memberships, audit log and stored files from the live service straight away.
- We keep encrypted nightly backups of the whole database, and an encrypted copy of uploaded files, for 35 days on a secured computer controlled by ES Dot Net in Malaysia. They cover every company together and exist only for our own disaster recovery: We may use them to try to bring the whole Service back after a major failure, but we do not promise that any data will be recovered. We do not restore or extract the data of an individual company or user from them, because doing so could put other customers' data at risk. We therefore cannot recover a company, file or record that you or your users have deleted or lost. A deleted company or file can remain in those backups until they are overwritten after 35 days.
- Application logs are kept for about 30 days. They may record that a deletion took place (company id, user id and time) but are not designed to hold accounting data.
- Untung chats (your questions, its answers and the figures shown) are visible in the Service only to the person who had the chat, not to other members or the company owner. A chat is deleted 7 days after its last message, or earlier if the company or your sign-in account is deleted, and may then remain in our encrypted backups for up to 35 days. Daily usage counts (number of questions and amount of AI processing, without the chat content) are kept for about 13 months for limits and billing. Chats are not included in the company data export; to get a copy of your chats or have them deleted sooner, email hello@untunglah.com.my. Google keeps its own copy for up to 55 days (see section 6).
- Scanned bills and receipts (the file you uploaded and what was read from it) belong to your company and are included in the company data export. A scan that is not turned into a bill is deleted automatically: 7 days after you discard it or it fails to read, or 60 days after you last touched it if you never reviewed it. The original of a scan that became a bill is kept for as long as that bill exists. Google keeps its own copy of what we send it for up to 55 days (see section 6).
- Support messages (your email address, company name and what you wrote) are kept while the request is open and deleted automatically 12 months after we close it. The support tools our staff use show your company's name, plan, payment history, number of users and last sign-in date to help you, and do not display your accounting records, contacts or chats.
- Billing and payment records are kept for about 7 years for tax and audit purposes.
- Your sign-in identity is separate from your companies. If you also want your sign-in account removed, email hello@untunglah.com.my. A sign-in account that belongs to no company and has not been used for 12 months may be deleted automatically, after we email its address at least 30 days beforehand; signing in during that time stops the deletion.
Malaysian law may require you, as a business, to keep accounting records for several years (for example under the Income Tax Act 1967). Keeping those records, and a copy of them outside Untunglah Pro, is your responsibility. Please export a copy regularly and before deleting a company, and keep your accounting records for the full retention period in both printed form (PDF and hard copy) and electronic form, stored outside Untunglah Pro. We do not keep your records on your behalf for that period: if you need to keep them for 7 years, keep your own copy.
9. Your rights under PDPA 2010
- Access: ask what personal data we hold about you. A company owner, or a user with the Company settings permission, can download all company data themselves from Settings > Company > Export all company data; attachments over the export size budget are provided on request by email. Untung chats are personal to you and are not in the company export; ask us by email for a copy.
- Correction: ask us to correct inaccurate or incomplete personal data. Most details can be edited directly in the Service.
- Data portability: you can take your company data with you in the export above, in standard formats, and ask us for help if you need it moved to another provider.
- Withdraw consent or limit processing: you may withdraw consent at any time, though we may then be unable to provide the Service.
- Deletion: company owners can delete a company at any time from the Companies page. For anything else, contact us.
- Marketing: we do not send marketing email from within the Service.
To use a right, email hello@untunglah.com.my. We will reply to access and correction requests within 21 days and do not charge a fee for them. We may ask you to prove your identity first. If your data is a business's record about you (see section 2), we will refer your request to that business, which is responsible for answering it.
11. Children
The Service is for businesses and is not directed at anyone under 18. If you think a minor has registered, email hello@untunglah.com.my and we will remove the account.
12. Changes to this policy
We may update this policy. For material changes we will email account owners or show a notice in the Service at least 14 days before they take effect. The date at the top shows when it was last revised.
13. Contact and complaints
Email hello@untunglah.com.my for any privacy question, request or complaint.
We will appoint a data protection officer and register with the Personal Data Protection Commissioner where the law requires it.
If you are not satisfied with our response you may complain to the Department of Personal Data Protection Malaysia (www.pdp.gov.my).