Digital Trustees Berhad – Will Writing Services via Gambit Will Plan Platform
1. Introduction
This Privacy Policy explains how Digital Trustees Berhad (“DTB”, “we”, “our” or “us”) collects, uses, processes, stores, discloses, and protects personal data in connection with the Will Writing Services provided through the Gambit Will Plan online platform hosted at gwp.digitaltrustees.com.my (“Platform”).
The Platform is provided, maintained, or operated by Gambit Will Plan as a technology platform and digital service channel for DTB. In this arrangement, DTB is the service provider for the Will Writing Services, while Gambit Will Plan may act as the technology platform provider, system operator, support provider, payment facilitation channel, data processor, or service support partner, where applicable.
By accessing the Platform, registering an account, submitting personal data, purchasing a package, making payment, or using the Will Writing Services, you (“Customer”, “you” or “your”) consent to the collection, use, disclosure, and processing of your personal data in accordance with this Privacy Policy the Personal Data Protection Act 2010.
2. Role of Digital Trustees Berhad
DTB is the service provider for the Will Writing Services made available through the Platform.
DTB may collect, use, process, store, disclose, and retain Customer’s personal data for the purpose of providing Will Writing Services, processing customer applications, preparing will documents, managing customer instructions, handling payment-related matters, responding to customer enquiries, maintaining records, and complying with legal or regulatory requirements.
3. Role of Gambit Will Plan Platform
Gambit Will Plan provides, maintains, or operates the Platform as a technology platform and digital service channel for DTB.
Gambit Will Plan may process personal data on behalf of DTB for purposes including customer registration, system hosting, account management, package selection, document workflow, payment facilitation, customer support coordination, technical support, security monitoring, platform maintenance, and other platform-related functions.
Unless expressly stated otherwise, Gambit Will Plan does not act as the will writing service provider, trustee, legal adviser, tax adviser, financial adviser, probate adviser, or estate administrator.
4. Personal Data We May Collect
We may collect personal data directly from you, from your authorised representative, from authorised agents, from the Platform, from payment service providers, or from documents and information submitted through the Platform.
The personal data we may collect includes:
a. full name;
b. NRIC, passport, or other identification number;
c. date of birth;
d. nationality;
e. gender;
f. marital status;
g. residential address;
h. correspondence address;
i. email address;
j. mobile number;
k. emergency contact details;
l. login and account details;
m. beneficiary details;
n. executor details;
o. guardian details, where applicable;
p. family relationship information;
q. asset and liability information;
r. will writing instructions;
s. supporting documents uploaded by you;
t. payment transaction details;
u. customer service records;
v. communication records;
w. device, browser, IP address, and platform usage information; and
x. any other information voluntarily submitted by you.
5. Confidential Estate Information
Will Writing Services may require the collection of confidential, or personal estate-related information, including family details, beneficiary details, executor details, guardian details, asset information, distribution instructions, and supporting documents.
You should only provide information that is accurate, necessary, and relevant to your will writing request.
If you provide personal data relating to another person, including beneficiaries, executors, guardians, family members, witnesses, authorised representatives, or emergency contacts, you confirm that you have the right or authority to provide such information to DTB and the Platform for the purpose of preparing, processing, storing, administering, or supporting your Will Writing Services.
6. Purpose of Collecting Personal Data
We may collect, use, and process your personal data for the following purposes:
a. to register and manage your account;
b. to verify your identity;
c. to process your application for Will Writing Services;
d. to prepare, draft, review, or update your will document;
e. to communicate with you regarding your service request;
f. to process payment, invoices, receipts, refunds, disputes, or chargebacks;
g. to provide customer support;
h. to manage amendments, confirmations, and service fulfilment;
i. to store records, documents, and transaction history;
j. to comply with legal, regulatory, tax, accounting, audit, or compliance obligations;
k. to prevent fraud, misuse, unauthorised transactions, or unlawful activity;
l. to improve the Platform, website, services, and customer experience;
m. to send service-related notices, updates, and reminders;
n. to manage complaints, enquiries, or disputes;
o. to protect DTB’s, Gambit Will Plan’s, customers’, and Platform users’ rights, property, platform security, and legal interests; and
p. for any other purpose reasonably related to the above.
7. Payment Information
Payments through the Platform may be processed by an appointed third-party payment gateway, bank, card processor, e-wallet provider, or payment service provider.
DTB and Gambit Will Plan do not store full credit card details, debit card details, online banking credentials, or e-wallet login credentials.
We may receive and store limited transaction-related information, including payment status, transaction reference number, payment amount, payment date, payment method, invoice number, order number, refund status, and chargeback status for accounting, audit, reconciliation, customer support, fraud prevention, and compliance purposes.
Payment processing may be subject to the privacy policy, security standards, and terms of the relevant payment service provider.
8. Disclosure of Personal Data
We may disclose your personal data to the following parties where necessary for the purposes stated in this Privacy Policy:
a. DTB’s directors, officers, employees, authorised personnel, agents, and representatives;
b. Gambit Will Plan, as technology platform provider, system operator, support provider, payment facilitation channel, data processor, or service support partner;
c. authorised agents, representatives, consultants, or service support personnel;
d. professional advisers, including lawyers, auditors, tax advisers, compliance advisers, or consultants;
e. payment gateway providers, banks, card processors, e-wallet providers, or payment service providers;
f. IT service providers, hosting providers, cloud service providers, software vendors, cybersecurity providers, and data storage providers;
g. document storage, record keeping, and administrative service providers;
h. customer support and communication service providers;
i. regulatory authorities, law enforcement agencies, government bodies, courts, or tribunals, where required;
j. parties involved in legal proceedings, disputes, investigations, audit, enforcement of rights, or compliance review; and
k. any other party where disclosure is necessary to provide the services, comply with legal obligations, or protect legitimate interests.
DTB ensures that all third parties handling personal data adhere to confidentiality and data protection standards equivalent to DTB’s.
9. Use of Personal Data by Gambit Will Plan
Gambit Will Plan may access, process, or store personal data only where necessary to support the operation of the Platform and delivery of the Will Writing Services.
This may include:
a. account registration and login management;
b. hosting and system maintenance;
c. customer dashboard and workflow management;
d. payment checkout and transaction support;
e. customer service coordination;
f. technical troubleshooting;
g. cybersecurity monitoring;
h. data backup and recovery;
i. system audit logs; and
j. platform improvement and operational reporting.
Gambit Will Plan is required to handle personal data in accordance with applicable data protection requirements, confidentiality obligations, and service arrangements with DTB.
10. Marketing Communications
We may use your contact details to send you updates regarding DTB’s services, promotions, estate planning packages, reminders, customer notices, or related information, where permitted by law.
You may opt out from receiving marketing communications by following the unsubscribe instructions or contacting us through the official support channel.
Even if you opt out from marketing communications, we may still send you service-related communications, including payment confirmation, account notices, document status updates, security alerts, policy updates, and transaction-related messages.
11. Cookies and Tracking Technologies
The Platform may use cookies, analytics tools, log files, device identifiers, or similar technologies to improve user experience, monitor website performance, remember preferences, analyse traffic, prevent fraud, enhance security, and improve service delivery.
You may adjust your browser settings to disable cookies. However, disabling cookies may affect certain website or Platform functions as some cookies are necessary for the operation of the Platform.
12. Accuracy of Personal Data
You are responsible for ensuring that all personal data submitted through the Platform or provided to DTB is accurate, complete, current, and not misleading.
You should notify DTB or the Platform support team promptly if there are any changes to your personal data, contact details, instructions, or submitted information.
DTB and Gambit Will Plan shall not be responsible for any error, delay, failed communication, incorrect document, dispute, or loss arising from inaccurate, incomplete, outdated, or misleading information provided by you.
13. Security of Personal Data
DTB and Gambit Will Plan will take reasonable administrative, technical, and organisational measures to protect personal data against unauthorised access, misuse, loss, alteration, disclosure, or destruction.
These measures may include access controls, password protection, secure servers, encryption where appropriate, audit logs, internal procedures, user access management, role-based access, data backup, and restricted access to confidential information.
However, no online platform, email transmission, cloud storage, or digital communication method is completely secure. Customers are responsible for protecting their own devices, passwords, email accounts, mobile numbers, and login credentials.
14. Retention of Personal Data
We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, provide the services, maintain records, comply with legal, regulatory, accounting, audit, tax, or operational requirements, resolve disputes, and protect legal interests.
When personal data is no longer required, DTB and/or Gambit Will Plan may securely delete, anonymise, archive, or restrict access to such data in accordance with internal retention practices and applicable legal requirements.
DTB may retain certain information where required by applicable law or for the establishment, exercise or defence of legal claims.
15. Access and Correction
You may request access to or correction of your personal data held by DTB or processed through the Platform, subject to applicable laws, verification requirements, and permitted exceptions.
DTB or the Platform support team may request proof of identity before processing any access or correction request.
Where permitted by law, DTB may refuse or limit access if the request is unreasonable, repetitive, affects the privacy of another person, relates to confidential commercial information, or is restricted by legal, regulatory, operational, or security considerations.
16. Withdrawal of Consent
You may withdraw your consent to the processing of your personal data by contacting DTB or the Platform support team through the official support channel.
However, withdrawal of consent may affect DTB’s ability to continue providing the Will Writing Services, maintain your account, process your request, store your documents, respond to enquiries, or comply with legal and regulatory obligations.
Withdrawal of consent shall not affect any processing carried out before the withdrawal or any processing required or permitted by law.
17. Personal Data of Third Parties
If you provide personal data of beneficiaries, executors, guardians, family members, witnesses, authorised representatives, or other third parties, you confirm that you have obtained the necessary consent or have lawful basis to provide such information to DTB and the Platform.
You agree to inform such third parties that their personal data may be provided to and processed by DTB, Gambit Will Plan, and authorised service providers for will writing, estate planning, record keeping, administration, verification, communication, legal, compliance, and related purposes.
18. Cross-Border Transfer
Where necessary, DTB or Gambit Will Plan may use service providers, systems, cloud platforms, software, or data storage facilities located within or outside Malaysia.
If personal data is transferred outside Malaysia, reasonable steps will be taken to ensure that the personal data remains protected in accordance with applicable data protection requirements.
19. Legal and Regulatory Disclosure
DTB or Gambit Will Plan may disclose personal data where required or permitted by law, regulation, court order, government request, regulatory requirement, enforcement action, audit, investigation, or legal proceeding.
Personal data may also be disclosed where necessary to protect rights, enforce terms, prevent fraud, detect suspicious activity, respond to disputes, or protect the safety and security of Customers, DTB, Gambit Will Plan, the Platform, or the public.
20. Children and Minors
The Will Writing Services are intended for Customers who are legally capable of making estate planning decisions.
We do not knowingly provide Will Writing Services to minors. If personal data of minors is provided in relation to guardianship, beneficiary, or family information, such data should only be submitted by a parent, guardian, or authorised person.
21. Third-Party Websites and Services
The Platform may contain links to third-party websites, payment gateways, service providers, or external platforms.
DTB and Gambit Will Plan are not responsible for the privacy practices, security, content, or terms of such third-party websites or services. Customers should review the applicable privacy policy and terms of those third parties before using their services.
22. Updates to This Privacy Policy
DTB may update this Privacy Policy from time to time to reflect changes in services, platform features, legal requirements, payment processes, data handling practices, technology arrangements, or business operations.
The latest version of this Privacy Policy shall be made available on the Platform or other official digital channel.
Continued use of the Platform or Will Writing Services after any update shall constitute acceptance of the revised Privacy Policy.
23. Contact Information
For questions, access requests, correction requests, withdrawal of consent, complaints, or enquiries regarding this Privacy Policy, Customers may contact DTB’s Data Protection Officer or the authorised Platform support team through the official customer service email, hotline, or support channel stated on the Platform.