Privacy Policy

1. Data Controller

The data controller responsible for your personal data is:

Capitaliq
19 Jalan Stonor, 50450 Kuala Lumpur, Malaysia
Email: [email protected]
Phone: +60 3-2174 8693

As a data controller, we are responsible for determining the purposes and means of processing your personal data and for ensuring that such processing complies with applicable Malaysian data protection law.

2. Personal Data We Collect

We collect personal data that you voluntarily provide to us and data collected automatically when you use our website. This includes, but is not limited to:

• Contact information: Full name, email address, phone number
• Enquiry and enrolment data: Program interest, questions submitted via contact forms, preferred contact method
• Payment data: Where applicable, billing information collected at the time of registration. We do not store full card details — payment processing is handled by authorised third-party payment processors.
• Usage data: IP address, browser type and version, operating system, pages visited, time and date of visit, referring URL, and other diagnostic data collected via cookies or analytics tools
• Communications: Records of correspondence with us via email or telephone

You are not obligated to provide all requested information. However, withholding certain data (such as contact details) may limit our ability to respond to your enquiries or process your enrolment.

3. Purpose of Processing

We process your personal data for the following purposes:

• To respond to enquiries and provide information about our programs
• To process and manage program enrolments and registrations
• To communicate program schedules, updates, and relevant materials
• To issue invoices and manage payment records
• To administer and improve our programs based on participant feedback
• To operate, maintain, and improve our website and digital services
• To comply with legal and regulatory obligations
• To send service-related communications (not marketing) that you have consented to receive

We do not sell your personal data to third parties for their marketing purposes.

4. Legal Basis for Processing

Under the Personal Data Protection Act 2010 (PDPA), we process your personal data on the following grounds:

• Consent: Where you have provided explicit consent, such as when submitting a contact form or opting in to communications
• Contractual necessity: Where processing is necessary to perform a contract with you (e.g., program enrolment)
• Legal obligation: Where processing is necessary to comply with applicable Malaysian law
• Legitimate interests: Where processing is in our legitimate interests and does not override your rights, such as fraud prevention and website security

5. Disclosure of Personal Data

We may share your personal data with the following categories of third parties, strictly for the purposes described in Section 3:

• Service providers: Technology providers, payment processors, and email service providers who assist us in operating our website and delivering programs. These parties are bound by data processing agreements and may not use your data for their own purposes.
• Analytics providers: Tools such as Google Analytics that help us understand how our website is used. Data shared is aggregated or pseudonymised where possible.
• Professional advisers: Lawyers, accountants, and auditors where required for legal and financial compliance.
• Regulatory authorities: Where required by Malaysian law, including disclosure to the Department of Personal Data Protection or other competent authorities.

We do not transfer your personal data outside Malaysia except where required by law or where adequate safeguards are in place as required under the PDPA.

6. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by Malaysian law.

• Enquiry data: Retained for up to 12 months from the date of last contact if no enrolment results
• Participant data: Retained for up to 7 years following program completion for financial and administrative records
• Website usage data: Retained for up to 26 months via analytics tools
• Marketing consent records: Retained for as long as consent is active and for 3 years following withdrawal

After the applicable retention period, your data will be securely deleted or anonymised.

7. Data Security

We implement reasonable technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include encrypted data transmission (HTTPS), access controls, and regular security reviews.

However, no method of transmission over the internet is completely secure. While we take reasonable precautions, we cannot guarantee absolute security of data transmitted to or from our website.

In the event of a data breach that is likely to result in significant harm to data subjects, we will notify the relevant authorities and affected individuals in accordance with our obligations under Malaysian law.

8. Your Rights Under the PDPA

As a data subject under Malaysia's Personal Data Protection Act 2010, you have the following rights:

• Right of access: You may request a copy of the personal data we hold about you
• Right of correction: You may request that inaccurate or incomplete personal data be corrected
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing
• Right to prevent processing: You may request that we cease or limit processing of your personal data in certain circumstances, such as where processing is causing or likely to cause damage or distress
• Right to prevent direct marketing: You may opt out of receiving any direct marketing communications from us at any time

To exercise any of these rights, please contact us at [email protected] or by post to our registered address. We will respond to your request within 21 days. In some cases, we may need to verify your identity before processing your request.

If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the Department of Personal Data Protection Malaysia (JPDP) at pdp.gov.my.

9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to operate effectively and to help us understand how visitors use the site. For detailed information about what cookies we use, why we use them, and how to manage your preferences, please read our Cookie Policy.

By continuing to use our website after accepting our cookie notice, you consent to our use of cookies as described in that policy.

10. Third-Party Links

Our website may contain links to third-party websites or services. We are not responsible for the privacy practices or content of those third parties. We encourage you to read the privacy policies of any external sites you visit.

11. Children's Data

Our programs and website are intended for adults (aged 18 and above). We do not knowingly collect personal data from individuals under the age of 18. If you believe we have inadvertently collected data from a minor, please contact us immediately and we will take prompt steps to delete it.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. When we make material changes, we will update the "Last Updated" date at the top of this document. We encourage you to review this policy periodically.

Continued use of our website or services following the posting of changes constitutes your acceptance of those changes to the extent permitted by applicable law.

13. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact us:

Capitaliq
19 Jalan Stonor, 50450 Kuala Lumpur, Malaysia
Email: [email protected]
Phone: +60 3-2174 8693
Office Hours: Monday to Friday, 9:00 AM – 5:30 PM MYT