Legal
Privacy Policy
Last Updated: 18 April 2025 · Warden & Co, Kuala Lumpur, Malaysia
Warden & Co ("we", "us", or "our") respects the privacy of all individuals who interact with our programmes, website, and communications. This policy explains what personal data we collect, how we use it, and the rights you have in relation to it.
This policy applies to personal data collected through our website at {{DOMAIN}}, through programme enrolment enquiries, and in the course of delivering our education programmes. It is governed by the Personal Data Protection Act 2010 (Malaysia) (PDPA).
For questions about this policy or to exercise your rights, please contact us at privacy@{{DOMAIN}}.
1. Personal Data We Collect
We collect personal data only for the purposes described in this policy. The categories of data we may collect include:
- Contact information: name, email address, phone number — collected through our website enquiry form or direct communication.
- Programme-related information: information you share during enrolment or sessions, including financial documents you bring for review purposes.
- Technical data: IP address, browser type, pages visited — collected automatically when you visit our website.
- Cookie data: preferences stored in your browser following your consent choices.
We do not collect sensitive personal data such as identification numbers, health data, or financial account credentials.
Legal Basis for Processing
We process your personal data on the following bases under the PDPA: consent (where you have given express permission), contractual necessity (where processing is required to deliver a programme you have enrolled in), and legitimate interests (for basic website analytics to improve our content).
Retention
Contact information submitted via enquiry forms is retained for up to 24 months from the date of your last interaction with us. Programme records are retained for 36 months after programme completion. Financial documents shared in sessions are not retained after the session concludes.
2. How We Use Your Personal Data
We use the personal data we collect for the following purposes:
- Responding to programme enquiries and providing programme information
- Processing enrolment and coordinating session schedules
- Delivering programme content and follow-up materials
- Sending administrative communications related to your programme
- Improving our website and understanding how it is used
We do not use your personal data for marketing communications without your explicit consent. We do not sell, rent, or otherwise transfer your personal data to third parties for commercial purposes.
Third-Party Services
We use a small number of third-party services to operate our website, including website analytics (which may collect anonymised visitor data) and email services for responding to enquiries. These providers process data only on our behalf and are contractually bound to protect it.
3. Data Protection Measures
We take reasonable steps to protect personal data against unauthorised access, disclosure, alteration, and loss. These measures include:
- HTTPS encryption for all website data transmission
- Access controls limiting who within our practice can view personal data
- No retention of financial documents shared during sessions after those sessions conclude
- Regular review of data handling practices
In the event of a data breach that affects your personal data, we will notify you and the relevant authority within the timelines required under Malaysian law.
4. Cookies
Our website uses cookies to function correctly and to help us understand how it is used. Essential cookies are required for the site to work; all other cookies are optional and require your consent. You can manage your cookie preferences at any time via our Cookie Policy page.
5. Your Rights Under Malaysian Law
Under the Personal Data Protection Act 2010 (Malaysia), you have the following rights in relation to your personal data:
- Right of access: You may request a copy of the personal data we hold about you.
- Right of correction: You may request that we correct inaccurate or incomplete personal data.
- Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time.
- Right to limit processing: In certain circumstances, you may request that we limit how we use your data.
- Right to prevent processing for direct marketing: You may opt out of any marketing communications at any time.
To exercise any of these rights, contact us at privacy@{{DOMAIN}}. We will respond within 21 days of receiving your request.
If you are unsatisfied with how we handle your personal data, you may lodge a complaint with the Personal Data Protection Department Malaysia (JPDP) at www.pdp.gov.my.
6. External 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 privacy policies separately.
7. Children
Our programmes are designed for adults aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18.
8. Updates to This Policy
We may update this policy from time to time to reflect changes in our practices or in applicable law. The current version will always be available at this address. We will notify enrolled participants of material changes by email.
9. Contact
For privacy-related questions or requests, please contact our data controller:
Warden & Co
Suite 9-3 Menara Wisma Warden, Jalan Yap Kwan Seng
50450 Kuala Lumpur, Federal Territory of Kuala Lumpur, Malaysia
Email: privacy@{{DOMAIN}}
Telephone: +60 3-2163 8745