Privacy Policy

1. Data Controller

The data controller for personal information collected through this website and through our services is:

Penserve
38 Jalan Padungan, 93100 Kuching, Sarawak, Malaysia
Email: [email protected]
Phone: +60 82 425 1738

2. Data We Collect

We collect the following categories of personal data:

• Identity data: name (first name, family name) provided when you submit an enquiry form.
• Contact data: email address and, if provided, telephone number.
• Communication data: the content of messages sent through our enquiry form.
• Technical data: IP address, browser type, device type, pages visited, and session duration, collected automatically through analytics cookies (if consented).
• Session notes: where you become a client, notes relating to your record organisation sessions are held in a password-protected file accessible only to the staff member conducting your session.

We do not collect sensitive personal data, financial account information, or copies of your personal documents.

3. Legal Basis for Processing

• Consent: when you submit an enquiry form or accept analytics cookies, you consent to the processing described in this policy. You may withdraw consent at any time.
• Contract: once you book a session, we process identity and contact data to deliver the service you have engaged.
• Legitimate interest: we may process technical data to maintain and improve our website, where this does not override your rights.

4. How We Use Your Data

• Responding to your enquiries and booking requests.
• Delivering and administering your session, including sending pre-session information and post-session materials.
• Sending service-related communications (not marketing) related to your booked programme.
• Improving the website based on aggregated, anonymised analytics data.
• Complying with applicable Malaysian law where required.

We do not use your personal data for direct marketing unless you have separately requested to be notified of new programmes, and you may withdraw that permission at any time by emailing [email protected].

5. Data Retention

• Enquiry data (name, email, message) from non-clients: retained for 6 months, then deleted.
• Session and client data: retained for 3 years from the date of the last session, then securely deleted.
• Analytics data: retained in aggregated form for 24 months, then purged.

6. Data Sharing

We do not sell, rent, or trade your personal data. We may share data with:

• Website hosting providers who process data on our behalf under appropriate data processing agreements.
• Analytics platforms (where you have accepted analytics cookies), which process data in aggregated form.
• Malaysian authorities where we are legally required to disclose information.

No personal data is transferred outside Malaysia without adequate safeguards in place.

7. Data Protection Measures

• HTTPS encryption on all website communications.
• Password-protected, access-controlled files for session notes.
• Internal access limited to staff with a direct need for the information.
• In the event of a data breach affecting your personal data, we will notify you within 72 hours of becoming aware, where required by law.

8. Cookies

We use essential cookies for basic site function and, where you consent, analytics cookies to understand how visitors use our site. For a full description of the cookies we use and how to manage your preferences, see our Cookie Policy.

9. Your Rights

Under Malaysia's Personal Data Protection Act 2010, you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Withdraw consent to processing at any time, without affecting the lawfulness of processing based on consent before withdrawal.
• Object to processing based on legitimate interest.
• Request deletion of your data, subject to our legal retention obligations.
• Lodge a complaint with the Department of Personal Data Protection Malaysia (JPDP) if you believe your rights have been infringed.

To exercise any right, email [email protected]. We will respond within 21 days.

10. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites. We encourage you to read the privacy policy of any external site you visit.

11. Children

Our services are intended for individuals aged 18 and above. We do not knowingly collect personal data from minors. If we become aware that personal data has been provided by a person under 18, we will delete it promptly.

12. Policy Updates

We may update this policy from time to time. Material changes will be notified by posting the revised policy on this page with an updated date. Continued use of the website after changes are posted constitutes acceptance of the revised policy.

13. Contact Us

For any questions or requests regarding this policy or your personal data, contact:

Penserve — Privacy Enquiries
38 Jalan Padungan, 93100 Kuching, Sarawak
Email: [email protected]
Phone: +60 82 425 1738