Privacy Policy

This Privacy Policy explains how Pointgate Systems Sdn Bhd (“Pointgate”, “we”, “us”) handles personal data in the smartid platform — EDUTIME, TIME, smartid POS, the smartid MOBILE app, and the palm terminals and scanners that work with them. It is written to comply with the Personal Data Protection Act 2010 of Malaysia (PDPA).

smartid is used by schools, universities, organisations and merchants to record attendance and, where enabled, to take cashless payments using contactless palm-vein recognition. Most personal data in smartid is entered by the institution that enrolled you, on its own behalf. In PDPA terms the institution is the data user for its people’s records, and Pointgate processes that data on the institution’s instructions. This policy describes what we do with it.

1. What we collect

1.1 Identity data

Your name, ID or passport number, system ID, email address, mobile number, user type (teacher, staff, student, employee, parent), and — for students — class, session and house. For staff, an emergency contact and, where the institution records it, a vehicle registration. Entered by your institution, or by you at registration.

1.2 Palm data

When you are enrolled, a contactless infrared scan of your palm is converted into a mathematical template — a set of numbers. No photograph or image of your hand is kept, and the template cannot be reversed into one. It is used only to recognise your palm again.

1.3 Attendance data

The date, time and method of each check-in and check-out (terminal, NFC card, mobile app or manual entry), the resulting status (on time, late, away, on leave, and so on), class roll marks, and any remark or correction an administrator makes. Corrections are logged with who made them and when.

1.4 Location data (mobile app only)

When you check in or out with the smartid MOBILE app, the app records the phone’s GPS position and accuracy at that moment, and an approximate street address derived from it. This decides whether the check-in happened at your institution’s registered premises, and the answer is stored with the record so it keeps saying what was true on the day. Location is read only at the moment you press check in or check out. The app does not track you in the background or while it is closed. If the phone reports that its position was simulated, that fact is stored with the check-in and shown to your administrator.

1.5 Leave and health data

Leave applications and their dates; where you submit a medical certificate or an absence note, the document you upload. Parents may submit medical or emergency leave for their children.

1.6 Family links

For a parent or guardian: which students are linked to you, so that you can see their attendance and payments. A parent sees only their own children.

1.7 Payment data

Payment and purchase transactions. Card and bank details entered for a payment go directly to the payment provider; we receive a confirmation and a reference, never the card number.

1.8 Merchant data (smartid POS)

Business name and registration details, operator accounts, sales items, orders, sales and expense records, and tax registration details where e-invoicing is enabled.

1.9 Device and technical data

Terminal and POS device identifiers used to register and secure each device, the app version, and operational logs (requests, errors, sign-in events) needed to run the service securely. The portal uses only the cookies needed to keep you signed in.

2. How sign-in works

The mobile app has no password. You sign in with a one-time code sent to the email address or mobile number your institution registered for you. We store that address or number so that the code can reach you; we do not store the code after it is used. Portal administrators sign in with email and password; passwords are stored only as salted hashes.

3. Why we use it

• To recognise enrolled people and record their attendance, class rolls and movements during the day.
• To operate leave, holiday and working-hour rules the institution has configured.
• To take cashless payments where the institution or merchant has enabled them.
• To give administrators dashboards, reports and exports for their own institution.
• To give parents a view of their own children’s attendance and payments.
• To bill the institution for its subscription.
• To keep the service secure: authenticating devices, refusing revoked enrolments, detecting simulated locations, and investigating misuse.
• To provide support when the institution asks for it.

We do not use personal data for advertising, we do not profile individuals for any purpose other than the ones above, and we do not sell it.

4. Palm data, specifically

• Palm templates are encrypted at rest and in transit.
• Matching happens on Pointgate’s own servers and on the institution’s own terminals. No palm data is sent to any third-party biometric or cloud recognition service.
• Templates are used only to identify you within smartid — for attendance and, where enabled, to confirm a payment. They are never used to identify you anywhere else.
• Enrolment requires your consent, and for anyone under 18 the consent of a parent or guardian, obtained and recorded by the institution. You may decline, and the institution must offer another method. You may withdraw consent by asking the institution to remove your enrolment; the template is then withdrawn from use and deleted under clause 8.

5. Where the data lives and how it is protected

• Data is hosted on servers operated for Pointgate, with an encrypted standby copy at a second site in case of failure. Failover is tested.
• All connections use HTTPS/TLS.
• Every institution’s data is separated from every other’s, and access within an institution is restricted by role and enforced at the database.
• Terminals and POS devices authenticate with individual credentials that can be revoked one at a time.
• Palm templates are also stored on the institution’s own terminals so that attendance works when the network is down; those copies are encrypted and are removed when the enrolment is revoked.
• Access by Pointgate staff is limited to what support and operation require and is logged.

6. Who sees it

• Your institution — administrators see the records of people at their own institution, in line with the roles the Super Admin has set. Teachers see their own classes. Staff see their own records.
• Parents and guardians — see their own children only.
• Merchants — see their own sales, orders and operators. A merchant sees a customer’s wallet transaction, not the customer’s attendance.
• Service providers — the categories are cloud hosting and backup; transactional email; payment processing; app distribution (Google Play, App Store). Each is bound by confidentiality and used only for that purpose. A current list is available to an institution on request.
• Authorities — where the law requires disclosure, or where it is necessary to protect the rights or safety of a person.

We do not transfer personal data outside Malaysia except to the extent a service provider named above operates infrastructure elsewhere, and then only under contractual protections.

7. Payments

Where your institution has enabled cashless payment, payments are made through a licensed payment provider. The provider handles the card or bank transaction and tells us only that it succeeded and for how much. Payments and purchases are visible to the account holder, to the parent for a child’s payments, and to the institution’s finance administrator. Palm-verified payments record the time, amount and merchant, not the palm data itself.

8. How long we keep it

• While you are enrolled — for as long as your institution keeps you as an active user and for the term of its subscription.
• When your enrolment is removed — your palm template is withdrawn from use immediately and deleted from our servers and from the institution’s terminals within 30 days. Your attendance history remains in the institution’s records because it is part of their register.
• When an institution leaves smartid — the institution has 30 days to export its reports. After that we delete its personal data, including all palm templates, within a further 30 days, except where the law requires us to keep transaction or tax records for longer.
• Operational logs are kept for up to 12 months for security and support, then deleted.

9. If something goes wrong

If we become aware that personal data we hold has been accessed without authority, we notify the affected institution’s Super Admin without undue delay and within 72 hours of confirming it, tell them what is known and what we are doing, and support the institution’s own notifications to affected people and, where required, to the Personal Data Protection Commissioner.

10. Children

smartid is deployed and operated by institutions, including schools. Where a child’s data is processed, it is on the instruction of the school, which is responsible for obtaining parental consent. Terminals are installed and operated by school staff. The mobile app is for staff, teachers and parents; a student does not need the app, and a parent’s access shows only that parent’s own children.

11. Your rights

Under the PDPA you may ask to:

• see the personal data held about you;
• correct data that is wrong or incomplete;
• withdraw consent to palm enrolment (the institution must then offer another method);
• limit how your data is used, where the law allows;
• know how your data is being processed.

Requests about attendance, leave or class records are best made to your institution, which controls those records and can act on them directly. You may also contact us at the address below; where the request concerns an institution’s records, we will refer it to the institution and help them respond.

12. Changes

We may update this policy. The date at the top shows the current version. Where a change affects how your data is used, we tell the institution’s Super Admin by email before it takes effect, and the institution informs its users.

13. Contact