Privacy Policy

1. Data Controller

Vellumora is the data controller for personal data collected through this website and in connection with our programme delivery. Our registered office is at Suite 11-2, Plaza Mont Kiara, 2 Jalan Kiara, 50480 Kuala Lumpur, Malaysia.

2. Personal Data We Collect

We collect the following categories of personal data:

Data You Provide Directly

• Name and contact details (email address, phone number) submitted via our enquiry form
• Organisation name and role, where provided voluntarily
• Message content submitted through the contact form
• Participant names and contact details collected for programme registration and administration

Data Collected Automatically

• Browser type, device type, and operating system (via analytics cookies, where consent is given)
• Pages visited and time spent on the website (aggregated, anonymised where possible)
• Referring website or search query leading to our site

Legal Basis for Processing

• Consent: For analytics and marketing cookies, where you have opted in via the cookie consent banner
• Contractual necessity: To process your enquiry, arrange programme delivery, and fulfil our service obligations
• Legitimate interests: To respond to general enquiries and improve our website and service quality

3. How We Use Your Personal Data

• To respond to enquiries submitted through our contact form
• To arrange, schedule, and deliver in-company sessions and annual programmes
• To send post-session memos and quarterly participation reports to programme organisers
• To process invoices and manage payment administration
• To improve our website and programme content based on aggregated usage data
• To comply with our legal obligations under Malaysian law

We do not use personal data collected through this website for unsolicited marketing communications. If you consent to receiving programme updates or news from Vellumora, you may withdraw that consent at any time by emailing [email protected].

4. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected:

• Enquiry records: Up to 12 months from the date of submission, unless an engagement commences
• Programme participant records: Up to 3 years from the date of programme delivery, for record-keeping and reporting purposes
• Invoice and payment records: 7 years, in accordance with Malaysian accounting requirements
• Website analytics data: Up to 26 months in aggregated form

When data is no longer required, it is deleted or anonymised.

5. Data Sharing

We do not sell, rent, or share personal data with third parties for their own marketing purposes. We may share data in the following limited circumstances:

• Service providers: Third-party platforms that support website hosting, email delivery, or document storage, where they are bound by appropriate data processing agreements
• Analytics providers: Where you have consented to analytics cookies, aggregated usage data may be processed by our analytics service provider
• Legal obligations: Where we are required to disclose data by law, regulation, or a lawful order from a Malaysian authority

6. Data Security

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

• Use of HTTPS encryption for all website communications
• Access controls limiting who within Vellumora can view client records
• Secure storage of electronic documents with access logging
• Regular review of data handling practices

In the event of a data breach that is likely to result in risk to affected individuals, we will notify the relevant parties as required under applicable Malaysian law and notify affected individuals where appropriate.

7. Cookies

Our website uses cookies to support basic functionality and, where consent is given, to collect aggregated analytics data. Cookie categories include essential cookies (always active), analytics cookies (optional), marketing cookies (optional), and preference cookies (optional).

You can manage your cookie preferences at any time through our Cookie Policy page. Withdrawing consent for optional cookies does not affect the lawfulness of any processing carried out before withdrawal.

8. Your Rights Under the PDPA (Malaysia)

Under the Personal Data Protection Act 2010 (Malaysia), you have the following rights in relation to personal data we hold about you:

• Right of access: To request a copy of the personal data we hold about you
• Right to correct: To request correction of inaccurate or incomplete personal data
• Right to withdraw consent: Where processing is based on consent, to withdraw that consent at any time
• Right to limit processing: To request that we restrict processing in certain circumstances
• Right to enquire: To make general enquiries about how your data is being handled

To exercise any of these rights, please contact us at [email protected]. We will respond within 21 days. If you are unsatisfied with our response, you may contact the Department of Personal Data Protection (JPDP) in Malaysia.

9. Third-Party Links

Our website may contain links to external websites. Vellumora is not responsible for the privacy practices of those third-party sites and encourages you to read their privacy policies before providing any personal data.

10. Children's Privacy

Our services are directed at organisations and professionals. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted personal data through our website, please contact us so we can delete it promptly.

11. Changes to This Policy

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

12. Contact

For any privacy-related enquiries, to exercise your data rights, or to raise a concern about how we have handled your personal data, please contact: