Privacy Policy
Last Updated: 10 May 2025 · Effective Date: 10 May 2025
1. Introduction
Sumber ("we", "us", "our") is committed to handling personal information responsibly and in compliance with Malaysia's Personal Data Protection Act 2010 (PDPA). This Privacy Policy explains what personal data we collect when you visit our website or enquire about our programmes, how we use it, and the choices you have.
If you have questions about this policy or wish to exercise any of your rights, please contact us at [email protected].
2. Data We Collect
2.1 Information you provide
When you complete an enquiry form or contact us directly, we may collect:
- Full name
- Email address
- Phone number (optional)
- Message content and enquiry details
2.2 Automatically collected data
When you visit our website, we may collect technical information including IP address, browser type, pages visited, and approximate location. This data is collected via cookies and analytics tools — see our Cookie Policy for full details.
2.3 Legal basis for processing
- Consent — for marketing communications and optional cookies
- Legitimate interest — for responding to enquiries and improving our website
- Contract performance — for processing enrolments and delivering programme services
2.4 Data retention
Enquiry data is retained for up to 24 months from the date of last contact. Programme participant records are held for up to 5 years for administrative and dispute resolution purposes. Analytics data is retained for up to 14 months.
3. How We Use Your Data
- To respond to enquiries and provide information about our programmes
- To process enrolments and administer participation in sessions
- To send programme-related communications (session reminders, materials)
- To send marketing communications, where you have given consent
- To improve our website and session content using aggregate analytics
- To comply with applicable legal obligations under Malaysian law
3.1 Marketing opt-out
If you receive marketing emails from us, each message includes an unsubscribe link. You may also opt out at any time by emailing [email protected].
4. Data Sharing
We do not sell personal data to any third party. We may share data with:
- Service providers — email delivery, website hosting, analytics tools — under data processing agreements
- Authorities — where required by Malaysian law or a valid legal order
We do not share participant business information disclosed in sessions with any external party for marketing or commercial purposes.
5. Data Security
We implement reasonable technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. These include:
- HTTPS encryption on all web communications
- Restricted staff access to personal data on a need-to-know basis
- Regular review of data handling procedures
In the event of a data breach that poses a risk to your rights, we will notify affected individuals and the relevant authority as required under applicable Malaysian law.
6. Cookies
We use cookies to support site functionality and, with your consent, to analyse site usage. See our Cookie Policy for a full explanation of the types of cookies used and how to manage your preferences.
7. Your Rights Under PDPA 2010
Under Malaysia's Personal Data Protection Act 2010, you have the right to:
- Access personal data we hold about you
- Request correction of inaccurate or incomplete data
- Withdraw consent to processing at any time (where processing is based on consent)
- Object to direct marketing use of your data
- Request restriction of processing in certain circumstances
To exercise any of these rights, contact us at [email protected]. We will respond within 21 days. We may ask you to verify your identity before acting on a request.
7.1 Complaints
If you believe we have not handled your data appropriately, you may lodge a complaint with the Department of Personal Data Protection Malaysia (PDPD). For information, visit www.pdp.gov.my.
8. Third-Party Links
Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and encourage you to review their policies separately.
9. Children's Privacy
Our programmes are designed for adults aged 18 and above. 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 and we will delete it promptly.
10. Policy Updates
We may update this policy from time to time. The "Last Updated" date at the top of this page will reflect any changes. Significant changes will be communicated via email to individuals on our mailing list. Continued use of our website after updates constitutes acceptance of the revised policy.
11. Contact
Data Controller: Sumber
Level 6, Plaza Sentral, Jalan Stesen Sentral 5, KL Sentral, 50470 Kuala Lumpur, Malaysia
Email: [email protected]
Phone: +60 3-2273 6048