Privacy Policy

Last updated: 1 January 2025  ·  Tunas Wealth, 39 Jalan Pinang, 50450 Kuala Lumpur

This Privacy Policy describes how Tunas Wealth ("we", "us", "our") collects, holds, uses, and discloses personal data in connection with our programmes, website, and communications. We are committed to handling personal data in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA).

1. Who This Policy Applies To

This policy applies to individuals who enquire about our programmes, register as participants, attend our sessions, or visit our website at tunaswea.club. It does not apply to data we hold about our staff or contractors, which is governed by separate arrangements.

2. Personal Data We Collect

We collect personal data that you provide directly to us, including:

  • Your full name, email address, and phone number when you submit an enquiry or register for a programme
  • Your occupation or employer, if you choose to provide this on our enquiry form
  • Payment information, processed through our payment provider — we do not retain full card details
  • Feedback and written responses submitted after sessions
  • Correspondence you send to us by email or post

We also collect limited technical data when you visit our website, including IP address, browser type, and pages accessed. This is collected through standard server logs and, where you have given consent, through cookies. Please refer to our Cookie Policy for details.

3. How We Use Your Personal Data

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

  • To respond to your enquiries and communicate with you about our programmes
  • To process programme registrations and payments
  • To send you pre-session reading materials and post-session notes where you are enrolled
  • To maintain records of programme attendance and feedback for internal quality purposes
  • To send occasional communications about upcoming cohorts, where you have not objected to receiving them
  • To comply with legal obligations, including financial record-keeping

We do not use your personal data for automated decision-making or profiling. We do not sell or rent personal data to third parties.

4. Legal Basis for Processing

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

  • Performance of a contract: when processing is necessary to fulfil a programme registration or respond to an enquiry
  • Consent: when you have given clear consent, for example by agreeing to receive programme communications
  • Legitimate interests: for internal record-keeping and quality improvement, where these interests do not override your rights
  • Legal obligation: where we are required to retain records under applicable law

5. How Long We Retain Your Data

We retain personal data for as long as is necessary for the purpose for which it was collected, and in any case for no longer than seven years after your last interaction with us, unless a longer period is required by law. Enquiry data where no registration follows is deleted after twelve months.

6. Sharing of Personal Data

We share personal data only in the following limited circumstances:

  • With our payment processing provider, for the purpose of completing programme fee transactions
  • With our email service provider, for the purpose of delivering programme communications
  • With professional advisers (legal, accounting) who are bound by confidentiality obligations
  • Where required by law, court order, or a regulatory authority

We do not transfer personal data outside Malaysia except where necessary to use internationally operated services (such as email or payment platforms). Where such transfers occur, we take reasonable steps to ensure appropriate safeguards are in place.

7. Your Rights Under the PDPA

Under the Personal Data Protection Act 2010, you have the right to:

  • Request access to personal data we hold about you
  • Request correction of inaccurate or incomplete personal data
  • Withdraw consent to the processing of your personal data, where processing is based on consent
  • Object to the use of your personal data for direct marketing purposes

To exercise any of these rights, please contact us at [email protected] or by post at 39, Jalan Pinang, 50450 Kuala Lumpur. We will respond within twenty-one days.

8. Security

We maintain reasonable physical, technical, and administrative safeguards to protect personal data from unauthorised access, use, or disclosure. These include restricted access to participant records, password protection of digital files, and use of reputable service providers. No data transmission over the internet is entirely secure; we cannot guarantee absolute security.

9. Cookies

Our website uses cookies. For details of what cookies we use and how to manage your preferences, please read our Cookie Policy.

10. Links to Other Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to read their privacy policies before providing any personal data to them.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page indicates when it was last revised. We will notify enrolled participants of material changes by email. Continued use of our website or programmes after any change constitutes acceptance of the updated policy.

12. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

  • Email: [email protected]
  • Phone: +60 3-2148 9376
  • Post: Tunas Wealth, 39, Jalan Pinang, 50450 Kuala Lumpur, Wilayah Persekutuan