Privacy Policy

1. Introduction

Gemilang Usaha ("we", "us", "our") is a business consulting practice registered in Malaysia, with its principal place of business at E-1-6, KL Eco City, Jalan Bangsar, 59200 Kuala Lumpur. We are committed to protecting the personal information of everyone who engages with our website and services.

This Privacy Policy applies to all information collected through our website at gemilan.club and through any consulting engagement. It is governed by Malaysia's Personal Data Protection Act 2010 (PDPA). If you have questions about this policy, please contact us at [email protected].

2. Personal Data We Collect

We collect only the information needed to provide our services and communicate effectively with you. This includes:

• Contact details such as your name, email address, and telephone number, provided when you complete an enquiry form or engage us for services.
• Business information such as your company name and nature of business, shared voluntarily during a consultation.
• Technical data such as your IP address, browser type, and pages visited, collected automatically when you use our website.
• Cookie data as described in our Cookie Policy, including preferences you select during your visit.

We do not collect sensitive personal data such as financial account details, identification numbers, or health information unless directly relevant to a service arrangement and provided by you with clear consent.

3. How We Use Your Personal Data

We process your personal data for the following purposes and on the following legal bases:

• Service delivery: To respond to your enquiries and provide the consulting services you have engaged us for. Legal basis: fulfilment of a contract or pre-contractual steps.
• Communication: To send you information relevant to your engagement, including session confirmations, written summaries, and follow-up correspondence. Legal basis: legitimate interest and consent.
• Website improvement: To understand how our website is used and make it more useful to visitors. Legal basis: legitimate interest.
• Legal compliance: To meet our obligations under Malaysian law, including the PDPA and applicable tax or business regulations. Legal basis: legal obligation.

We do not use your personal data for automated decision-making or profiling.

4. Sharing Your Data

We do not sell, rent, or trade your personal information. We may share data in limited circumstances:

• With service providers who assist in operating our website and delivering services — for example, hosting providers and email services — under contractual obligations of confidentiality.
• With professional advisors such as accountants or legal counsel, strictly as required.
• With Malaysian regulatory authorities when required by law or in response to a lawful request.

Any third party processing data on our behalf is required to handle it in a manner consistent with this policy and the PDPA.

5. Data Retention

We retain personal data only for as long as necessary:

• Contact enquiry data is retained for up to 12 months from the date of last contact if no engagement results.
• Client engagement records are retained for seven years from the end of the engagement, in line with standard business record-keeping obligations under Malaysian law.
• Website analytics data is retained in aggregated, anonymised form and not linked to individuals after 13 months.

Once data is no longer needed, we securely delete or anonymise it.

6. Security Measures

We take reasonable technical and organisational steps to protect your personal data from unauthorised access, loss, or misuse. These include:

• TLS encryption for data transmitted through our website.
• Access controls limiting personal data to staff members who need it to do their work.
• Regular review of data handling practices.
• Secure storage of written client records.

In the event of a data breach that is likely to affect your rights or interests, we will notify you and the relevant authority as required under the PDPA.

7. Cookies

Our website uses cookies to maintain basic functionality and, with your consent, to understand how visitors use the site. Cookies fall into four categories: essential, analytics, marketing, and preference. Essential cookies are necessary for the site to function and cannot be disabled. The others are optional and controlled by you.

For full details on the cookies we use and how to manage your preferences, please see our Cookie Policy.

8. Your Rights

Under the Malaysian Personal Data Protection Act 2010, you have the right to:

• Access the personal data we hold about you.
• Correct any personal data that is inaccurate or incomplete.
• Withdraw consent for processing activities based on your consent, at any time.
• Request cessation of processing where it is causing or is likely to cause distress or harm.
• Complain to the Department of Personal Data Protection (JPDP) if you believe your rights under the PDPA have been infringed.

To exercise any of these rights, please write to us at [email protected]. We will respond within 14 days of receiving your request.

9. Third-Party Links

Our website may occasionally contain links to external websites. We are not responsible for the privacy practices of those websites and encourage you to review their policies independently. This Privacy Policy applies solely to information collected by Gemilang Usaha.

10. Children's Privacy

Our services are intended for business owners and individuals aged 18 and above. We do not knowingly collect personal data from persons under 18. If we become aware that data from a minor has been submitted, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. When we do, we will revise the "Last Updated" date at the top of this page. Where changes are material, we will take reasonable steps to make you aware of them.

Continued use of our website or services after a revised policy is posted constitutes your acknowledgement of the changes.

12. Contact for Data Enquiries

If you have any questions about how your personal data is handled, or if you wish to exercise your rights, please contact our data privacy contact: