FinPool Privacy Policy (DRAFT)

Draft of 2 November 2026, adapted from the SalesPool policy. LEGAL-REVIEW: whole page needs legal review.

1. Who we are

FinPool is run by DIGITAL AGE INTELLIGENCE MANAGEMENT, a sole proprietorship registered in Malaysia – SSM 201903107602 (002960128-X) – of 1-6-24 Permai Court 1, Jalan 16A, Taman Dato' Ahmad Razali, 68000 Ampang, Selangor ("we", "us"). Contact: support@stirlingsmarttools.com. We follow the Malaysian Personal Data Protection Act 2010 (PDPA) and, where they apply, Singapore's PDPA and the GDPR. Our data protection contact is Nurhazzarita binti Holil (support@stirlingsmarttools.com).

2. What data we collect and why

Account: name, email, country and sign-in records, to run your account.

Business details: business name, address, phone, country and tax IDs (TIN, BRN, SST and MSIC). A MyKad number, if you give one, is stored encrypted. We use these to issue your invoices and, when you turn it on, your e-invoices.

Your customers and suppliers: names, contact details, addresses and tax IDs you enter. A customer's MyKad number is stored encrypted. You must have the right to store this data.

Invoices, expenses and receipts: the documents and photos you add, to keep your books. Receipt photos are read by xAI's AI service to fill in the expense; you check the result before saving.

Security: audit logs and IP-based country, to keep the service safe and show the right country page.

3. LHDN e-invoice (Malaysia)

When e-invoicing is live and you authorise FinPool as your intermediary in the MyInvois portal, we send your invoice data, including your and your buyer's tax IDs, to LHDN on your behalf, and keep LHDN's validation results. You can remove the authorisation in MyInvois at any time. LEGAL-REVIEW: confirm wording once LHDN sandbox testing is done.

4. Who we share data with

We use service providers only to run FinPool: Cloudflare (hosting, database, storage), payment and email providers, xAI (reading receipt photos for receipt scans), and LHDN when you use e-invoicing. LEGAL-REVIEW: confirm the provider list. We do not sell personal data.

5. How long we keep data

Accounting records and invoices are kept for as long as Malaysian law requires (currently 7 years), even after you close your account, unless you export and the law lets us delete them. Other data is deleted within 30 days of account deletion. LEGAL-REVIEW: confirm periods against the app's retention rules.

6. Cookies

This website sets one cookie, fp_country, to remember the country page you picked. It is not used for tracking.

Website analytics: we use Google Analytics (GA4), which sets cookies, to count visits and see which pages and buttons (for example WhatsApp, email, sign-up and Play Store links) are used. It gives us statistics, not your name. We do not use advertising cookies on this site unless you opt in where a cookie choice is shown. Google processes this data for us. You can opt out with the Google Analytics opt-out browser add-on, or by declining analytics cookies where we offer that choice, or by blocking cookies in your browser.

Analytics cookies load only after you accept them on the cookie bar, or from account settings in the FinPool app.

7. Your rights

You can ask to see, correct, export or delete your data, or object to how we use it, by emailing Nurhazzarita binti Holil at support@stirlingsmarttools.com. You can also complain to your data protection authority.

8. Changes

If we change this policy, we will update the date above and tell you about important changes in the app or by email.