Privacy Policy

1. Who We Are

Data controller: Tanjong Forge, Level 5, Southkey Mosaic, Jalan Bakti, 80150 Johor Bahru, Johor, Malaysia.

For any privacy-related enquiries, contact us at [email protected] or by post to the address above.

2. Information We Collect

We may collect the following categories of personal information:

• Contact details: name, business name, telephone number, and email address submitted through our contact form or provided directly during an engagement.
• Enquiry content: the message or description of your operational situation that you include in a contact form submission.
• Usage data: pages visited, time spent on pages, referring URLs, device type, and browser type, collected via analytics tools.
• Cookie data: preferences and session identifiers stored in your browser as described in our Cookie Policy.

We do not collect sensitive personal data (such as identification numbers, health information, or financial account details) through our website.

3. How We Collect Information

• Directly from you: when you complete and submit our contact form.
• Automatically: through cookies and analytics tools when you visit our website.
• In the course of an engagement: through working sessions, correspondence, and documents shared as part of an advisory arrangement.

4. Legal Basis for Processing

We process personal data on the following grounds:

• Consent: where you have given clear consent for a specific purpose, such as accepting cookies or opting into communications.
• Legitimate interest: to respond to enquiries, manage our business relationships, and improve our website.
• Contract: to deliver advisory services where an engagement has been agreed.
• Legal obligation: where we are required to retain or disclose data under Malaysian law.

5. How We Use Your Information

• To respond to enquiries submitted via our contact form.
• To deliver advisory engagements and communicate during the course of a project.
• To keep records of past engagements for continuity and reference.
• To understand how our website is used and make improvements.
• To meet any legal or regulatory obligations that apply to our business.

We do not use personal data for automated decision-making or profiling.

6. Sharing Your Information

We do not sell, rent, or trade personal data. We may share information in the following limited circumstances:

• Service providers: third-party tools that help us operate our website (such as analytics or email services), who are contractually required to protect data and use it only for the purpose for which it was shared.
• Legal requirements: where disclosure is required by Malaysian law, a court order, or a regulatory authority.
• Business transfers: if the business is transferred or merged, personal data may be transferred to a successor, subject to this policy.

7. Data Retention

• Contact form submissions: retained for up to 24 months from the date of submission, or for as long as needed to respond to your enquiry.
• Engagement records: retained for up to 7 years following the end of an engagement, for professional record-keeping and any potential legal requirements.
• Analytics data: retained in aggregate, anonymised form; individual session data is not retained beyond 14 months.
• Cookie data: as specified in our Cookie Policy.

8. Data Security

We take reasonable technical and organisational measures to protect personal data, including:

• Encrypted transmission via HTTPS for all website traffic.
• Access restricted to individuals who need it to carry out their work.
• Regular review of access permissions.
• Secure storage of engagement documents.

No transmission or storage system is entirely secure. In the event of a data breach that is likely to result in risk to your rights and freedoms, we will notify affected individuals and the relevant authority as required under the PDPA.

9. Cookies

Our website uses cookies to support basic functionality and to understand how visitors use the site. Cookie categories include essential, analytics, marketing, and preference cookies. You may manage your preferences at any time through our Cookie Policy page.

10. Your Rights

Under the PDPA and applicable Malaysian law, you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete personal data.
• Withdraw consent for processing based on consent, without affecting the lawfulness of prior processing.
• Object to processing for direct marketing purposes.
• Request deletion of personal data where there is no compelling reason to continue processing it.
• Lodge a complaint with the Personal Data Protection Commissioner (PDPC) of Malaysia if you believe your data has been handled unlawfully.

To exercise any of these rights, contact us at [email protected]. We will respond within 21 days.

11. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and encourage you to review their policies independently. This policy applies only to our own website and engagements.

12. Children's Privacy

Our services are directed at businesses and business professionals. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted data through our site, please contact us at [email protected] and we will remove it promptly.

13. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or applicable law. The revised policy will be posted on this page with an updated "Last Updated" date. Continued use of our website after a policy change constitutes acceptance of the updated terms. For material changes, we will make reasonable efforts to notify affected users.

14. Contact Us

For any questions, requests, or concerns relating to this privacy policy or how we handle personal data:

• Email: [email protected]
• Address: Tanjong Forge, Level 5, Southkey Mosaic, Jalan Bakti, 80150 Johor Bahru, Johor, Malaysia
• Phone: +60 7-336 8421