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Legal Document

Privacy Policy

Sinar takes your privacy seriously. This policy describes what information we may collect when you visit our website or contact us, how we use it, and how we keep it safe. We have written it in plain language so it is easy to follow.

Last Updated: 20 May 2025  ·  Effective Date: 20 May 2025

01 Introduction

Sinar ("we", "us", "our") is an AI integration consulting practice based at No. 31, Jalan Tengku Kelana, 41000 Klang, Selangor, Malaysia. We provide advisory and implementation services to small businesses exploring the use of everyday technology tools.

This Privacy Policy applies to all personal data we receive through our website at https://sinarmy.club, our contact form, and any direct communication you initiate with us. By using our website or submitting your details, you acknowledge that you have read and understood this policy.

We operate in accordance with the Personal Data Protection Act 2010 (PDPA) of Malaysia. We do not sell your data, and we only hold what we genuinely need to respond to your inquiry or deliver agreed services.


02 Data We Collect

We collect personal data in a limited and purposeful way. The categories of information we may hold are described below.

Information you provide directly

  • Name — so we know how to address you properly.
  • Email address — our primary way of responding to your inquiry.
  • Phone number — if you choose to share it, for follow-up calls.
  • Message content — the details you share about your business situation or questions.

Information collected automatically

  • Analytics data — pages visited, time spent, browser type, and general location (country/city), collected through Google Analytics if you consent to analytics cookies.
  • Cookie data — small files stored on your device to maintain essential website functions and, with your consent, to understand how visitors use our site.

Legal basis for processing

  • Consent — for analytics and marketing cookies, and for sending you information you request.
  • Legitimate interest — responding to an inquiry you have initiated and maintaining the security of our website.
  • Contractual necessity — processing your data to deliver a service you have engaged us for.

Retention: Inquiry data is held for up to 2 years after your last contact. Client engagement data is held for 7 years for financial record-keeping purposes, as required under Malaysian law. Analytics data is retained according to the third-party provider's schedule (typically 26 months for Google Analytics).


03 How We Use Your Information

Your data is used only for purposes that are directly related to our services or the operation of this website:

  • Responding to your inquiries and questions about our services.
  • Scheduling and conducting consultation sessions when you choose to proceed.
  • Delivering agreed services (workshop facilitation, implementation support, companion plan guidance).
  • Sending information you have specifically requested, such as a plain-language summary after an Orientation Workshop.
  • Understanding how visitors use our website so we can make it more helpful (analytics, with your consent).
  • Meeting our legal and regulatory obligations under Malaysian law.

We do not: sell your data to third parties, use it for unsolicited marketing, or share it with any party that does not need it to help us deliver our services.

Third-party processors: We use Google Analytics (anonymised website analytics) and may use standard email services for correspondence. These processors operate under their own privacy frameworks and data processing agreements with us.


04 Data Protection Measures

We take reasonable and appropriate steps to protect the personal data we hold. Our measures include:

  • HTTPS encryption — all data transmitted between your browser and our website is encrypted in transit using TLS.
  • Access controls — only team members who need your information to respond to you or deliver services can access it.
  • Secure storage — records are stored using services that maintain industry-standard security practices.
  • Breach notification — in the event of a data breach affecting your personal data, we will notify you and the relevant authority (the Personal Data Protection Commissioner) within the timeframes required by Malaysian law.

While no system is completely without risk, we review our data practices regularly and adjust them as our operations change.


05 Cookies

Our website uses cookies — small text files placed on your device — to keep certain functions working and to understand how visitors interact with our pages. We use four categories:

  • Essential cookies — always active; these are necessary for the website to function (e.g. remembering your cookie preferences).
  • Analytics cookies — only with your consent; used to understand which pages are visited and how long visitors stay, helping us improve our content.
  • Marketing cookies — only with your consent; used by advertising services (such as Meta Pixel or Google Ads) to show relevant content to visitors who have previously visited our site.
  • Preference cookies — only with your consent; used to remember your settings and language choices.

You can manage your cookie preferences at any time by visiting our Cookie Policy page, which includes controls to change your selections.


06 Your Rights

Under the Personal Data Protection Act 2010 (Malaysia), you have rights in relation to the personal data we hold about you. These include:

Right to Access

You may request a copy of the personal data we hold about you.

Right to Correction

You may ask us to correct inaccurate or incomplete data.

Right to Erasure

You may ask us to delete data we no longer have a legal reason to hold.

Right to Object

You may object to processing based on legitimate interest.

Withdraw Consent

You may withdraw consent for analytics or marketing cookies at any time.

Lodge a Complaint

You may contact the Personal Data Protection Commissioner at pdp.gov.my if you feel your rights have not been respected.

To exercise any of these rights, please write to us at [email protected]. We will respond within 21 days.


07 Third-Party Links

Our website may occasionally contain links to external websites for reference or convenience. Once you leave our site, this Privacy Policy no longer applies. We are not responsible for the data practices of any third-party site and encourage you to review their privacy policies before sharing personal information.


08 Children's Privacy

Our services are intended for business owners and their representatives, who are generally 18 years of age or older. We do not knowingly collect personal data from anyone under 18. If you believe a minor has submitted information through our website, please contact us at [email protected] and we will promptly delete it.


09 Policy Updates

We may update this policy from time to time as our practices evolve or as required by changes in Malaysian law. When we make material changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically. Continued use of our website after an update constitutes acceptance of the revised policy.


10 Contact for Privacy Matters

If you have any questions about this policy, wish to exercise your rights, or want to know more about how we handle your data, please reach out to us:

Sinar — Data Controller

No. 31, Jalan Tengku Kelana, 41000 Klang, Selangor, Malaysia