Privacy Policy
Last Updated: 15 June 2025 · Effective: 15 June 2025
1. Data Controller
The data controller responsible for your personal data is Lumivest, located at Jalan Tun Sambanthan, 50470 Kuala Lumpur, Malaysia. You may contact us regarding data matters at [email protected] or by phone at +60 3-7981 2634.
2. Data We Collect
We collect personal data when you submit an enquiry form, enrol in a programme, or contact us directly. The categories of data we may collect include:
- Full name
- Email address
- Phone number (if provided)
- Message content you submit through our contact form
- Programme enrolment and participation records
- Website usage data collected via cookies and analytics tools (see Section 6)
We collect only what is necessary for the purpose stated at the point of collection. We do not collect sensitive personal data such as financial account details, government identification numbers, or health information.
3. Legal Basis for Processing
We process your personal data on the following legal grounds under the PDPA 2010:
- Consent: Where you have provided explicit consent, such as when submitting an enquiry form.
- Contractual necessity: Where processing is required to deliver the educational programme you have enrolled in.
- Legitimate interests: For improving our website and communicating programme updates to existing participants, where this does not override your rights.
4. How We Use Your Data
Your personal data is used for the following purposes:
- Responding to enquiries submitted through our contact form
- Managing your enrolment in a Lumivest programme
- Sending programme-related communications (schedules, access details, updates)
- Improving our educational content and website experience based on aggregated usage data
- Complying with applicable legal obligations
We do not use your personal data for automated decision-making or profiling in a way that produces significant legal effects.
5. Data Sharing
We do not sell, rent, or trade your personal data with third parties for marketing purposes. We may share data with:
- Service providers who assist in programme delivery (e.g., secure hosting providers, communication platforms) under contractual obligations to protect your data
- Regulatory bodies or law enforcement where required by applicable Malaysian law
Any third-party service providers we engage are required to handle your data solely for the purpose for which it was shared, and not to use it for their own commercial purposes.
6. Cookies and Analytics
Our website uses cookies to understand how visitors use the site and to maintain basic session functionality. Types of cookies we use include essential cookies (required for the site to function), analytics cookies (to understand page usage patterns), and preference cookies (to remember your consent choices). You can manage your cookie preferences at any time through our Cookie Policy page. Accepting or rejecting non-essential cookies does not affect your ability to access our content or contact form.
7. Data Retention
We retain personal data for as long as is necessary for the purpose it was collected, or as required by law:
- Enquiry form data: up to 12 months from date of submission if no enrolment follows
- Programme participant records: up to 3 years from programme completion for administrative purposes
- Website analytics data: in aggregated, anonymised form for up to 24 months
After the retention period, data is securely deleted or anonymised.
8. Data Security
We take reasonable and appropriate technical and organisational measures to protect your personal data from unauthorised access, loss, or misuse. These measures include:
- HTTPS encryption for all data transmitted through our website
- Access controls limiting who within Lumivest can access personal data
- Regular review of our data handling processes
In the event of a data breach that is likely to adversely affect your rights, we will notify affected individuals and, where required, the relevant authority in a timely manner.
9. Your Rights
Under the Personal Data Protection Act 2010, you have the following rights in relation to your personal data:
- Right of access: To request a copy of the personal data we hold about you
- Right of correction: To request correction of inaccurate or incomplete data
- Right to withdraw consent: To withdraw consent for processing at any time (this does not affect the lawfulness of processing before withdrawal)
- Right to limit processing: To request that we limit how we use your data in certain circumstances
To exercise any of these rights, please contact us at [email protected]. We will respond within 21 days of receiving your request. If you are unsatisfied with our response, you may lodge a complaint with the Personal Data Protection Commissioner of Malaysia.
10. Third-Party Links
Our website may contain links to external websites, including regulatory bodies and official resource portals. Lumivest is not responsible for the privacy practices of those third-party sites. We encourage you to review the privacy policies of any external sites you visit.
11. Children's Privacy
Lumivest programmes are intended for adults aged 18 and above. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been collected from a minor, we will delete it promptly. Parents or guardians who believe their child has submitted data to us are encouraged to contact us at [email protected].
12. International Data Transfers
Your personal data is processed and stored in Malaysia. If any data is transferred to a third-party service provider outside Malaysia, we ensure that appropriate safeguards are in place in accordance with the PDPA 2010 before any such transfer occurs.
13. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. Continued use of our website or programmes after changes are made constitutes your acknowledgement of the updated policy. For material changes, we will provide notice through the website or by email to programme participants.
14. Contact Us
For any questions or concerns about this Privacy Policy or your personal data, please contact: