1. Who We Are
This Privacy Policy explains how FCPOfolio ("we", "us") collects, uses and protects your personal data. We are a Personal Data Protection Act 2010 (Act 709) compliant platform operated by [business name, SSM registration no., address]. Our privacy contact is [support email].
2. What We Collect
We collect personal data you provide when you register or subscribe: your name, email address, and billing references. Card payment details are handled by our payment gateway and are not stored by us. We also collect limited usage data and cookies to operate and improve the Platform.
3. Purposes of Processing
We process your personal data for: creating and managing your membership, processing subscription payments, delivering content and features, sending service and marketing communications, analytics, and meeting legal and tax obligations.
4. Legal Basis & Consent
We process your personal data with your consent and for lawful purposes directly related to the Platform's activity. Supply of personal data is voluntary, but certain data is required to provide membership services — if you do not supply it, we may be unable to provide those services.
5. Disclosure to Third Parties
We disclose personal data only to the classes of third parties needed to run the Platform: payment gateway providers, email delivery providers, analytics providers, hosting providers, and authorities where required by law. We do not sell your personal data.
6. Cross-Border Transfers
Some service providers (such as analytics and email providers) are located outside Malaysia. Where personal data is transferred across borders, we rely on the exceptions under s.129 of the PDPA (as amended), including your consent to such transfer.
7. Cookies & Analytics
We use cookies and analytics tools to understand how the Platform is used and to improve it. You can control cookies through your browser settings.
8. Security
We apply practical safeguards including encryption in transit and access controls to protect your personal data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. Retention
We keep your account data while you are a member and for as long as required by law, including statutory record-keeping periods for tax and audit purposes. We delete or anonymise personal data no longer needed.
10. Your Rights
You have the right to request access to and correction of your personal data, to limit its processing, and to withdraw consent at any time. To exercise these rights, contact us at [support email]. A nominal fee may apply for access requests as permitted by the PDPA. You also have the right to lodge a complaint with the Personal Data Protection Commissioner.
11. Marketing Choices
We send marketing communications only with your consent. You may opt out of direct marketing at any time through the unsubscribe link in any email or by contacting us.
12. Breach Notification
In the event of a notifiable personal data breach, we will notify the Personal Data Protection Commissioner within 72 hours of becoming aware of the breach and will notify affected data subjects, as required by the PDPA (Amendment) Act 2024.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be notified on the Platform or by email. Continued use after changes take effect constitutes acceptance.
14. Contact
Questions about this policy or your personal data should be sent to [support email]. This policy is governed by the laws of Malaysia.