Privacy Policy

1. Introduction

Sinar Council Sdn. Bhd. ("Sinar Council", "we", "us") is committed to protecting the personal data of individuals who interact with us through our website and through our advisory engagements. This policy describes what personal data we collect, why we collect it, how we use it, and the rights available to individuals under applicable Malaysian law.

This policy applies to personal data collected via our website at sinarcous.site, through our contact forms, and through correspondence related to our advisory services. It does not cover data collected by third-party websites that may be linked from our pages.

By using our website or submitting an enquiry, you acknowledge that you have read and understood this policy. If you have questions, write to us at [email protected].

2. Data We Collect

We collect personal data only where there is a clear reason to do so. The categories of data we may collect include:

• Contact details provided through our enquiry form: name, email address, phone number
• The content of messages submitted through our contact form
• Technical data collected automatically when you visit our website: IP address, browser type, pages visited, time of visit
• Cookie preference data stored in your browser's localStorage when you interact with our cookie consent notice

We do not collect sensitive personal data (such as identification numbers, financial data, or health information) through our website. Data shared during an advisory engagement is governed by the separate engagement agreement and its confidentiality provisions.

Legal basis for processing

We process personal data on the following legal bases under the Personal Data Protection Act 2010 (Malaysia) ("PDPA 2010"):

• Consent — where you have given explicit consent, such as by submitting an enquiry form
• Contractual necessity — where processing is required to respond to an enquiry or carry out an engagement
• Legitimate interests — where processing is necessary to operate and improve our website, provided your rights are not overridden

3. How We Use Your Data

Personal data collected through our website is used for the following purposes:

• To respond to enquiries submitted through our contact form
• To assess whether an engagement is suitable and to communicate with prospective clients
• To maintain records of client communication for the duration of and following an engagement, as required by our professional obligations
• To understand how our website is being used and to identify technical issues

We do not use personal data for direct marketing or for any automated decision-making. We do not sell or rent personal data to third parties.

Data retention

Enquiry data is retained for twelve months from the date of receipt, after which it is securely deleted unless an engagement has commenced. Data arising from an engagement is retained for five years from engagement close, as required by our professional and legal obligations. Website analytics data is retained in aggregated, anonymised form only.

4. Data Sharing

We do not share personal data with third parties except in the following limited circumstances:

• With our website hosting provider, solely for the purpose of operating the website, under a data processing arrangement that restricts use to that purpose
• Where required by law, regulation, or an order of a Malaysian court or authority
• With our professional advisers (legal counsel, accountants) where necessary and subject to professional confidentiality obligations

We do not transfer personal data outside of Malaysia without appropriate safeguards. We do not use third-party advertising networks or social media tracking pixels on our website.

5. Cookies and Website Analytics

Our website uses cookies and similar technologies. Essential cookies are required for the website to function. Optional cookies (analytics, preferences) are set only with your consent, which you can give or withdraw via our cookie notice.

We use a minimal analytics setup to understand general patterns of website use (pages visited, general geographic region, browser type). We do not use Google Analytics or similar third-party analytics services that track individuals across multiple websites. Analytics data is not linked to any personal identifier.

For detailed information on the cookies we use and how to manage your preferences, see our Cookie Policy.

6. Data Security

We take the security of personal data seriously. Measures in place include:

• HTTPS encryption on all pages of our website
• Access to personal data restricted to the consultant(s) involved in the relevant engagement or enquiry
• Secure, password-protected storage for all digital records containing personal data
• A documented procedure for identifying and responding to personal data breaches, including notification to affected individuals and to the relevant authority where required by law

No method of data transmission or storage is entirely without risk. We will notify you promptly if we become aware of a breach affecting your personal data.

7. Your Rights

Under the Personal Data Protection Act 2010 (Malaysia) and applicable regulations, you have the following rights in relation to your personal data:

• The right to access personal data we hold about you
• The right to correct inaccurate or incomplete personal data
• The right to withdraw consent where processing is based on consent
• The right to request that we cease processing your data for direct marketing purposes (though we do not currently conduct direct marketing)
• The right to request deletion of your personal data where there is no continuing lawful basis for its retention

To exercise any of these rights, write to us at [email protected]. We will respond within 21 days. We may ask you to verify your identity before processing a request.

If you are not satisfied with our response, you may lodge a complaint with the Department of Personal Data Protection Malaysia (JPDP): www.pdp.gov.my.

8. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies before providing any personal data to them.

9. Children's Privacy

Our services are directed at established businesses and their principals. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have inadvertently collected data from a minor, we will delete it promptly.

10. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or in applicable law. When we do, we will update the "Last Updated" date at the top of this page. If changes are material, we will take reasonable steps to bring them to the attention of individuals whose data we hold. Continued use of our website following an update constitutes acceptance of the revised policy.

11. Contact and Data Controller Details

The data controller for personal data collected through this website is:

Sinar Council Sdn. Bhd.
Suite 21-3, Menara KLK
No 1 Jalan PJU 7/6
47810 Petaling Jaya
Selangor, Malaysia

For privacy-related enquiries: [email protected]

For general enquiries: [email protected]  ·  +60 3-7849 6132