Privacy Policy

1. Who We Are

The data controller for information collected through this website and through our programme delivery is Brevora, operating from Level 9, Menara Hap Seng 2, Plaza Hap Seng, 50050 Kuala Lumpur, Malaysia. Contact: [email protected].

2. Information We Collect

We collect personal information in the following ways:

• Contact forms: Name, email address, and phone number when you submit an enquiry through our website.
• Programme enquiries: Additional information about your organisation, team size, and commercial context shared during pre-programme briefings.
• Programme participation: Notes and reflections shared during programme sessions, which are treated with strict confidentiality as described in our programme terms.
• Website analytics: Technical data about how visitors use our website (pages visited, time on site, browser type), collected through cookies when consent has been given.

We do not collect sensitive personal data (such as financial or health information) through our standard enquiry processes.

3. Legal Basis and How We Use Information

We use personal information for the following purposes, each with a corresponding legal basis under the PDPA:

• Responding to enquiries (legitimate interest / consent): When you contact us, we use your name and contact details to respond and discuss your requirements.
• Programme delivery (contractual basis): Where an engagement is agreed, we use contact and organisational information to plan, deliver, and follow up on the programme.
• Communication about our programmes (legitimate interest): We may send information about Brevora programmes to enquirers who have not yet proceeded. You may opt out at any time.
• Website improvement (legitimate interest): Analytics data helps us understand how visitors use the site and make appropriate adjustments.

4. Data Retention

We retain personal data for the following periods:

• Enquiry records: Up to 24 months from last contact, unless an engagement proceeds.
• Programme participant records: Up to 36 months following completion of the engagement.
• Analytics data: Aggregated analytics retained for up to 26 months; individual session data for up to 14 months.
• Billing and administrative records: As required by Malaysian law, typically up to 7 years.

5. Sharing of Information

We do not sell personal information to third parties. We may share information with:

• Service providers: Technology platforms used to deliver programme communications, such as email services. These providers process data on our behalf and are bound by appropriate data processing terms.
• Professional advisers: Accountants and legal advisers where necessary for business operations, subject to confidentiality obligations.
• Legal requirements: Where required by Malaysian law or lawful authority.

Programme participant information shared during sessions is not disclosed to organisers at an individual level without the participant's knowledge, except in the limited case of feedback notes agreed as part of the programme structure.

6. Data Security

We take reasonable and appropriate measures to protect personal information against unauthorised access, disclosure, or loss. These include:

• Encrypted transmission of data via our website (HTTPS)
• Access controls limiting who within Brevora can access personal information
• Regular review of data held and deletion of information no longer required

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

7. Cookies

Our website uses cookies to operate correctly and, where consent is given, to collect analytics data. For full details of the cookies we use and how to manage your preferences, please see our Cookie Policy. You can withdraw cookie consent at any time through your browser settings or via the preferences page.

8. Your Rights

Under the Personal Data Protection Act 2010 (Malaysia), you have the following rights regarding your personal data:

• Right of access: You may request a copy of the personal information we hold about you.
• Right of correction: You may request that inaccurate information be corrected.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
• Right to prevent processing for direct marketing: You may request that we cease using your information for direct marketing purposes.
• Right to lodge a complaint: You may lodge a complaint with the Department of Personal Data Protection Malaysia if you believe your rights have been infringed.

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

9. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and recommend that you review their privacy policies independently before providing any personal information.

10. Children's Privacy

Our programmes and services are directed at professionals and commercial teams. We do not knowingly collect personal information from persons under the age of 18. If you believe a minor has submitted information through our website, please contact us so we can remove it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When changes are material, we will update the "Last Updated" date at the top of this page. Continued use of our website or services following a policy update constitutes acceptance of the revised policy. We recommend reviewing this page periodically.

12. Contact

For any privacy-related questions or requests:

• Email: [email protected]
• Address: Level 9, Menara Hap Seng 2, Plaza Hap Seng, 50050 Kuala Lumpur, Malaysia
• Phone: +60 3 2386 5247