Privacy Policy

Last updated: 25 June 2025  ·  Effective: 25 June 2025

Sirih Circle ("we", "us", "our") is committed to handling personal information responsibly and in accordance with the Personal Data Protection Act 2010 (PDPA) of Malaysia. This policy explains what personal data we collect, how we use it, how we protect it and what rights you have in relation to it.

1. Data Controller

The data controller for personal information collected through this website and through our programmes is Sirih Circle, 76 Jalan Gaya, 88000 Kota Kinabalu, Sabah, Malaysia. For data-related enquiries, contact us at [email protected].

2. What Personal Data We Collect

We collect personal data only when it is provided to us directly. This includes:

• Name, when you submit an enquiry form or register for a programme
• Email address, when you submit an enquiry form or register for a programme
• Telephone number, if you choose to provide it
• The content of messages you send through our enquiry form
• Basic usage data collected through cookies, where consent has been given

We do not collect sensitive personal data. We do not collect copies of identity documents, financial records or family documents. Session facilitators do not retain the names or personal circumstances of participants.

3. How We Use Personal Data

Personal data submitted through our enquiry form is used solely to respond to your enquiry and, where relevant, to confirm programme registration. We do not use your contact details for marketing without your express consent. Specifically:

• Enquiry data is used to respond to your question and provide any information you requested
• Registration data is used to confirm your place, provide session details and send relevant pre-session materials
• We do not sell, rent or share your personal data with third parties for their marketing purposes

4. Legal Basis for Processing

Under the PDPA 2010, we process personal data on the following grounds:

• Your consent, given when you submit an enquiry form or register for a programme
• Legitimate interest, in maintaining records necessary to manage programme administration
• Compliance with legal obligations, where applicable

5. Data Retention

Enquiry records are retained for twelve months from the date of submission, after which they are deleted unless an ongoing programme relationship exists. Programme registration records are retained for three years to meet administrative obligations, then deleted. You may request earlier deletion (see Section 8).

6. Data Protection Measures

Personal data submitted through this website is transmitted over encrypted connections (HTTPS). Access to contact and registration records is restricted to the administrative staff who need it to respond to your enquiry or manage your programme registration. We review our data handling practices against current published guidance periodically.

7. Cookies

This website uses cookies to support basic site functionality. Details of the cookies used, their purpose and how to manage them are set out in our Cookie Policy.

8. Your Rights

Under the PDPA 2010, you have the right to:

• Access the personal data we hold about you
• Correct personal data that is inaccurate or incomplete
• Withdraw consent to the processing of your personal data
• Request the deletion of your personal data, subject to any legal retention obligations
• Object to the processing of your personal data for purposes other than those stated in this policy

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

9. Third-Party Services

This website uses third-party services for analytics and maps where consent has been given. These services may set their own cookies. We are not responsible for the privacy practices of third-party services. Links on this website to external resources are provided for information only; we are not responsible for their content or privacy practices.

10. Children's Privacy

Our programmes are intended for adults. We do not knowingly collect personal data from anyone under 18 years of age. If you believe we have inadvertently collected such data, contact us at [email protected] and we will delete it promptly.

11. Policy Updates

We may update this policy from time to time to reflect changes in our practices or in applicable law. The updated version will be published at this URL with a revised "Last updated" date. Continued use of this website after an update constitutes acceptance of the revised policy.

12. Contact

For any question about this policy or about how we handle your personal data, write to us at [email protected] or by post to Sirih Circle, 76 Jalan Gaya, 88000 Kota Kinabalu, Sabah, Malaysia.