Privacy Policy

1. About This Policy

This Privacy Policy describes how Lumenpath ("we", "us", "our") collects, uses, stores and protects personal information when you interact with our website at lumenpat.cyou or engage with our advisory services. We are committed to handling personal information with care and in a manner consistent with the Personal Data Protection Act 2010 (PDPA) of Malaysia.

By using our website or contacting us, you acknowledge that you have read and understood this policy.

2. Information We Collect

We may collect the following categories of personal information:

• Contact details — name, email address, phone number, and organisation name, provided when you submit an enquiry through our website or contact us directly.
• Correspondence — records of communications between you and Lumenpath, including email exchanges and notes from discussions.
• Usage data — information about how you navigate and interact with our website, collected through analytics tools. This may include your IP address, browser type, pages visited and time spent on each page.
• Cookie data — small data files placed on your device to help us understand site usage and improve your experience. See our Cookie Policy for full details.

We do not collect sensitive personal data (such as financial account details, identification numbers or health-related information) through our website.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• To respond to your enquiries and provide information about our services.
• To deliver advisory engagements you have requested, including scheduling, correspondence and reporting.
• To maintain records of our professional relationships and engagements.
• To improve our website and understand how visitors engage with our content.
• To send service-related communications, where you have made an enquiry or entered an engagement.
• To fulfil obligations under applicable law or regulation.

We do not use your personal information for unsolicited marketing communications, and we do not sell or rent personal data to third parties.

4. Legal Basis for Processing

We process personal information on the following grounds:

• Consent — where you have submitted a contact form or otherwise provided information voluntarily.
• Contractual necessity — where processing is required to deliver services you have engaged us for.
• Legitimate interests — where we have a reasonable business interest, such as improving our services or maintaining records, and that interest is not outweighed by your rights.
• Legal obligation — where we are required to process information to comply with applicable Malaysian law.

5. Sharing of Information

We do not share your personal information with third parties except in the following circumstances:

• Service providers — trusted third-party tools we use to operate our website or deliver services (such as hosting providers or analytics platforms). These parties are bound by confidentiality obligations and may not use your data for their own purposes.
• Legal requirements — where we are required to disclose information by law, regulation, court order or government authority.
• Business transfers — in the event of a merger, acquisition or transfer of business assets, personal information may be transferred as part of that transaction, subject to the same protections described in this policy.

6. Data Retention

We retain personal information for as long as is necessary for the purposes outlined in this policy, or as required by law. In practice:

• Enquiry records are retained for up to 24 months from the date of last contact.
• Records relating to completed engagements are retained for up to 7 years for professional and legal purposes.
• Analytics and cookie data is retained in accordance with the settings of the respective tools used.

When personal information is no longer required, we delete or anonymise it in a secure and orderly manner.

7. Your Rights

Under the PDPA and general principles of fair data handling, you have the right to:

• Request access to personal information we hold about you.
• Request correction of inaccurate or incomplete personal information.
• Withdraw consent for processing, where consent is the legal basis.
• Request that we cease using your personal information for direct marketing purposes.

To exercise any of these rights, please contact us at [email protected]. We will respond within a reasonable period and, where applicable, within the timeframes required by law.

8. Security

We take reasonable technical and organisational steps to protect personal information from unauthorised access, loss, misuse or alteration. These measures include secure data transmission, access controls and periodic review of our data handling practices.

While we take appropriate precautions, no method of transmission over the internet is entirely secure. If you have concerns about the security of information you have shared with us, please contact us directly.

9. Third-Party Links

Our website may contain links to third-party websites. This policy does not apply to those sites. We encourage you to review the privacy policies of any third-party sites you visit, as we have no control over their content or data practices.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we do, we will update the "Last updated" date at the top of this page. We encourage you to review this policy periodically.

11. Contact

If you have questions about this Privacy Policy or how we handle your personal information, please contact us:

• Email: [email protected]
• Phone: +60 11-2748 3905
• Address: Level 9, Block 3750, CoMTech, Persiaran APEC, 63000 Cyberjaya, Selangor, Malaysia