Legal & Transparency
Privacy Policy
Caldwynn is committed to handling personal information with care and transparency. This policy describes what data we collect, how we use it, and what rights you have regarding your information.
Last Updated: 14 May 2025 | Effective: 14 May 2025
01 / Introduction
This Privacy Policy applies to the website at caldwynn.sbs and to the advisory services provided by Caldwynn, registered and operating from Level 9, Menara Hap Seng, Jalan P. Ramlee, 50250 Kuala Lumpur, Malaysia.
By using this website or contacting us through it, you acknowledge that you have read and understood this policy. If you have questions about any section, please reach out using the contact details at the end of this document.
This policy is governed by the Personal Data Protection Act 2010 (PDPA) of Malaysia. Where we engage with individuals or organisations from other jurisdictions, we aim to apply the relevant protections those locations require as well.
02 / Data We Collect
We collect personal data in the following situations:
Information you provide directly
When you submit an enquiry through our contact form, we collect your name, email address, phone number (if provided), and any message content you choose to share. This data is used solely to respond to your enquiry and to follow up on any subsequent advisory engagement.
Information collected automatically
When you visit our website, standard server logs may record your IP address, browser type, the pages you viewed, and the time and date of access. We also use cookies and similar technologies, as described in Section 5 of this policy.
Legal basis for processing
- Your consent, given when you submit a form or accept cookies
- Legitimate interest in operating a functional, secure website
- Pre-contractual steps, when responding to an advisory enquiry
Retention periods
Contact enquiry data is retained for up to 24 months. Website log data is retained for up to 12 months. Cookie preference records follow the durations described in our Cookie Policy. You may request earlier deletion at any time.
03 / How We Use Your Data
Data collected through this website is used for the following purposes:
- Responding to enquiries — we use your contact details to reply to messages and to follow up if appropriate.
- Service delivery — if an advisory engagement proceeds, contact information is used to manage communication throughout.
- Website improvement — aggregated, anonymised analytics help us understand how the site is used and where it can be made clearer.
- Legal compliance — we may retain or disclose data if required by Malaysian law or by a valid legal process.
We do not sell, rent, or trade personal data with third parties for their marketing purposes. We do not send unsolicited marketing communications. If you have made an enquiry with us and we send you a follow-up message, you may opt out of further contact at any time by replying with a withdrawal request.
04 / Data Protection Measures
We take reasonable technical and organisational steps to protect personal data from unauthorised access, disclosure, alteration, or destruction. These include:
- Transport encryption (HTTPS/TLS) on all pages of this website
- Access controls limiting which staff can view contact data
- Regular review of data handling practices
- Use of reputable service providers for hosting and infrastructure
No method of transmission over the internet is completely secure. While we apply reasonable safeguards, we cannot warrant the absolute security of any information transmitted to us.
In the event of a data breach that affects your personal information, we will notify affected individuals and, where required, the relevant Malaysian authority in accordance with applicable requirements.
06 / Your Rights
Under Malaysia's Personal Data Protection Act 2010 and, where applicable, internationally recognised data protection principles, you have the following rights:
Right of Access
Request a copy of the personal data we hold about you.
Right to Correct
Ask us to update or correct inaccurate information.
Right to Erasure
Request deletion of your data, subject to legal retention requirements.
Right to Object
Object to processing based on legitimate interests.
Right to Portability
Receive your data in a structured, readable format.
Withdraw Consent
Withdraw previously given consent at any time.
To exercise any of these rights, contact us at [email protected]. We aim to respond within 21 days. If you believe your rights have not been adequately addressed, you may raise a concern with Malaysia's Department of Personal Data Protection (JPDP).
07 / Third-Party Links
This website may contain links to external websites operated by third parties. We have no control over the content or privacy practices of those sites and are not responsible for them. We recommend reviewing the privacy policy of any external site you visit through a link on our pages.
08 / Children's Privacy
This website and Caldwynn's advisory services are directed at business professionals and organisations. We do not knowingly collect personal data from individuals under 18 years of age. If we become aware that we have inadvertently collected such data, we will delete it promptly. If you have reason to believe a minor has submitted information through this website, please contact us.
09 / Policy Updates
We may update this policy periodically to reflect changes in our practices, technology, or applicable law. The date at the top of this page will reflect when the policy was last revised.
For material changes that significantly affect how we handle your data, we will make reasonable efforts to notify affected individuals — for example, through a notice on this site or direct communication where we have contact details on file. Continued use of the website after an update constitutes acceptance of the revised policy.
10 / Contact Information
Data Controller: Caldwynn