1. Who handles your information
The platform operator is Smart Butler Sdn Bhd, registration number 202501020174 (1621587-H). Its contact details appear below. The company name displayed in your workspace identifies the subscriber administering that workspace; it is not necessarily Smart Butler Sdn Bhd.
Smart Butler handles its own account, subscription, support and security information. For property records processed on a subscriber's instructions, the subscriber may act as the data controller and Smart Butler as its data processor. Roles depend on the actual processing and applicable arrangements. A subscriber's separate notice may also apply to its tenancy and property-management activities.
2. Information the platform can handle
The information involved depends on the features you use and the records supplied by your organisation. Not every field is collected from every user.
- Account and contact information: name, email, telephone number, organisation, role, invitations and authentication records.
- Property and tenancy records: property/unit/space details, occupant or owner information, rental periods, agreements, emergency contacts and uploaded identity documents where supplied.
- Profile information supplied for property administration, such as nationality, race, gender, occupation and identity numbers; collect only what is appropriate and necessary.
- Financial and document records: bank details where supplied, invoices, deposits, expenses, claims, receipts, payment references and uploaded supporting evidence.
- Operational and technical records: assigned meter identifiers, consumption and credit readings, enabled smart-access records, device/browser information, IP addresses, security logs, audit events and support correspondence.
3. Where information comes from
Information may come directly from you, from the subscriber or its authorized staff, from owners or tenants involved in the relevant property relationship, from documents they upload, or from configured payment, email, meter and access providers.
Some technical records are generated when the service is used or when an integration reports an event. If another person supplies your information, contact the responsible workspace administrator or Smart Butler to ask about its source and purpose.
4. Why information is processed
The proposed purposes are to provide the requested account and workspace access; administer property and tenancy relationships; prepare and retrieve documents; process and reconcile payments, deposits, claims and top-ups; supply authorized owner/tenant views; provide support; protect accounts; investigate incidents; and maintain appropriate transaction and audit records.
Processing should be limited to a relevant, disclosed purpose and an applicable legal basis, consent or statutory exception. Where sensitive personal data is involved, additional requirements may apply. Do not upload unnecessary sensitive information or another person's data without appropriate authority.
Optional marketing is separate from account access and service messages. Reading this policy is not blanket consent to unrelated marketing or new uses of personal information.
5. Required information and your choices
Information needed to identify an invited user, verify access, administer a tenancy, prepare a document or execute a requested payment may be required for that particular service. Without it, the relevant account or transaction may not be completed. Optional contact details, profile fields and attachments should be supplied only where relevant; the responsible organisation should identify which fields it requires and why.
You may ask about limiting processing or withdrawing consent where applicable using the contact details below. Some processing or records may need to continue where lawfully required. A limitation can affect the service concerned; its consequences should be explained, rather than treating every field as compulsory.
6. Access and disclosures
Information may be available to the subscriber's authorized staff and, where relevant and authorized, the owner or tenant associated with the particular record. Assigning an expense to a tenancy or owner account is not itself permission to disclose all its attachments or internal notes.
Relevant information may be processed by contracted hosting, storage, email, support, payment, meter or smart-access providers. Depending on the configured integrations, examples include Cloudflare R2 for file storage and Xendit for hosted checkout; this is not a complete, confirmed deployment-provider list. Providers receive the information appropriate to the enabled service and applicable arrangements.
Information may also need to be disclosed to professional advisers or authorities where lawfully required. The final notice must identify the applicable recipient classes and any additional disclosures. Unrelated marketing, sale or other secondary use must not be assumed from acceptance of platform terms.
7. Payments and supporting documents
Hosted payment providers process checkout information under their own applicable notices. Smart Butler can receive payment identifiers, status updates, amounts and related references needed for reconciliation. Bank information, receipts and claim evidence supplied to the workspace can contain personal information and should be shared only with appropriate recipients.
Check the named merchant, payee and provider before submitting payment information. Do not send passwords, one-time codes or unnecessary full payment credentials in a claim attachment or support email.
9. Storage and overseas processing
Personal information may be processed outside Malaysia if the configured hosting or integrated providers operate there. The actual destinations, provider access and safeguards have not yet been confirmed for this notice.
Before an effective notice is approved, the operator and relevant subscriber must confirm the overseas processing and applicable transfer conditions, and provide the required information and choices. Publishing this draft or obtaining general Terms acceptance does not by itself establish a lawful cross-border transfer.
10. Security and retention
The platform includes authentication, permission checks and audit mechanisms intended to restrict access and support investigation. No online service can guarantee absolute security. Report a suspected exposure or unauthorized account activity promptly without including unnecessary sensitive information in your report.
Information should be retained only for the relevant operational purpose and lawful requirements, with appropriate handling of backups, audit records and legal holds. Closing an account does not automatically delete a subscriber's issued documents or records it must lawfully retain.
Exact retention periods, backup expiry, deletion procedures, support access and incident-response arrangements must be verified and approved. This draft does not promise immediate deletion, a fixed retention period or a particular security certification.
11. Requests and complaints
Contact info@smartbutler.com.my to ask about your information, request access or correction, withdraw applicable consent, object to direct marketing, or raise a privacy complaint. Other requests, including portability or deletion, will depend on applicable law, technical feasibility and lawful retention requirements; this draft does not promise an unconditional right to erase all records.
Identify the workspace and request without sending an unredacted identity document unless specifically required through an appropriate secure channel. Identity and authority may need to be verified. Where a subscriber controls the relevant records, the request may need to be coordinated with that subscriber.
If a concern is not resolved, you may contact Malaysia's Personal Data Protection Commissioner through the official Personal Data Protection Department channels. The final procedure must confirm request handling, verification and any applicable statutory deadlines.
12. Changes and contact
The final policy should state its effective date and version and explain significant changes before processing changes where required. New purposes or disclosures may require an updated notice and additional choices or consent. No new consent is recorded merely by viewing this draft.
For platform questions, use the company contact details below. A subscriber should separately identify its contact for tenancy or property-management information. Smart Butler's operator details must not be silently replaced by subscriber workspace branding.
Items to confirm before approval
- Confirm the deployed providers, recipient classes, storage destinations and cross-border safeguards.
- Confirm cookie/storage lifetimes, optional tracking and any marketing practices.
- Approve a retention and backup-deletion schedule and account-closure/export procedures.
- Confirm subscriber/controller and platform/processor responsibilities in appropriate agreements.
- Confirm request handling and incident procedures, and assess applicable DPO and breach-notification obligations.
- Obtain Malaysian legal review, approve both languages and set an effective date.
Contact the platform operator
Smart Butler Sdn Bhd
- Registration number
- 202501020174 (1621587-H)
- Address
- 4, Lorong Singgora, 10150 Georgetown, Penang, Malaysia
- Phone
- +60 10-547 6618
- Privacy and platform contact
- info@smartbutler.com.my
- Additional email
- smartbutler.pg@gmail.com