Privacy Policy

1. Introduction

Willowmark is committed to handling personal data responsibly and in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA 2010). This policy explains what personal data we collect when you use our website or enquire about our programmes, how we use it, and what rights you have in relation to it.

If you have questions about this policy or about how we handle your data, contact us at [email protected].

2. What Personal Data We Collect

Data you provide directly

• Name and email address (required when you submit an enquiry)
• Phone number (optional, if you provide it)
• Any details you include in your message

Data collected automatically

• Browser type, operating system, and IP address (via server logs)
• Pages visited and time spent on pages (via analytics cookies, if consented)
• Referring website or search query that brought you to the site

Data we do not collect

We do not collect payment card details. Programme fees are handled through bank transfer or payment methods agreed at the point of enrolment. We do not collect data relating to children under 18.

3. Legal Basis for Processing

• Consent: For analytics cookies and marketing communications, where you have opted in.
• Contractual necessity: When you enrol in a programme, we process your name and contact details to manage your enrolment and communicate about sessions.
• Legitimate interests: We may process contact information to respond to enquiries you have initiated, which we consider a legitimate interest that does not override your rights.
• Legal compliance: We retain certain records to comply with Malaysian tax and administrative requirements.

4. How We Use Your Data

• To respond to your enquiries about programmes
• To process and manage programme enrolments
• To send you programme-related communications (session reminders, materials notices)
• To improve our website and understand how visitors use it (analytics only if consented)
• To comply with legal and administrative obligations under Malaysian law

We do not use your personal data to build marketing profiles or pass it to advertising networks. We do not sell personal data to third parties.

5. Data Retention

• Enquiry data (no enrolment): retained for 12 months, then deleted.
• Enrolment records: retained for 7 years following programme completion, in accordance with Malaysian record-keeping requirements.
• Analytics data: aggregated and anonymised after 26 months.
• Cookie consent records: retained for 13 months from date of consent.

6. Third-Party Services

We may use the following third-party services, each with their own privacy terms:

• Google Analytics — website usage data (if analytics cookies consented). Google Privacy Policy
• Google Maps — embedded map on our homepage for location display only. No personal data is submitted via the map embed.
• Email and hosting providers — used to receive and respond to enquiries; selected for compliance with data protection standards.

We do not share personal data with third parties for their own marketing purposes.

7. Cookie Use

Our website uses essential cookies (necessary for the site to function), and optional analytics cookies. You can manage your cookie preferences at any time through our Cookie Policy page. Essential cookies cannot be disabled.

8. Your Rights Under the PDPA 2010

Under Malaysia's Personal Data Protection Act 2010, you have the following rights in relation to your personal data held by us:

• Right of access: You may request a copy of personal data we hold about you.
• Right to correction: You may request correction of inaccurate or incomplete data.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect processing carried out before withdrawal.
• Right to object: You may object to processing in certain circumstances.
• Right to limit processing: You may request that we restrict how we use your data in certain circumstances.

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

9. Data Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, or loss. Access to personal data is limited to staff who need it to perform their role. Our website uses HTTPS encryption for data in transit. In the event of a data breach that affects your rights, we will notify you as required by law.

10. External Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites. We recommend reviewing their privacy policies before providing any personal data.

11. Children's Privacy

Our programmes and website are intended for adults aged 18 and above. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected such data, please contact us so we can delete it.

12. Changes to This Policy

We may update this privacy policy from time to time. The date at the top of the page reflects when it was last revised. Continued use of the website following any update constitutes acceptance of the revised policy.

13. Contact for Data Enquiries

Willowmark
38 Jalan SS 15/4, 47500 Subang Jaya, Selangor, Malaysia
Email: [email protected]
Phone: +60 3 5621 8479