PERSONAL DATA PROTECTION POLICY ('PRIVACY POLICY')

This Personal Data Protection Policy (“Privacy Policy”) describes how Magcolm Solutions Sdn Bhd (“MAGCOLM”) (Registration No: 201301042053 (1071878-U)) collects, uses and protects your Personal Data.

INTRODUCTION

This policy outlines the commitment of Magcolm Solutions Sdn Bhd to protect your personal data in accordance with the Personal Data Protection Act 2010 and its amendments. We are dedicated to safeguarding your personal data collected through our online Learning Management System (LMS), remote online and physical training sessions.

1. DEFINITION OF PERSONAL DATA

In the course of your dealings with Magcolm Solutions, we will request that you provide personal data to enable us to enter into commercial transaction with you or to deliver the necessary services in connection to our business.

“Personal Data” refers to any information that relates to an identified or identifiable individual. This includes, but is not limited to:

a) Basic Personal Information: Names, identity card numbers, date of birth and gender

b) Contact Information: Home address, business address, email addresses and phone numbers

c) Financial Information: Banking details, credit card information and payment history

d) Professional Information: Job title, employment history, qualifications and resumes or CVs

e) Health Information: Any data related to health status or medical history

f) Biometric Data: Fingerprints, facial recognition data and other biometric identifiers

g) Sensitive Personal Data: Information that reveals racial or ethnic origin, political opinions, religious beliefs and trade union membership

This definition includes new categories introduced in the 2024 amendments, ensuring comprehensive coverage of all relevant aspects of personal data.

2. CONSENT REQUIREMENTS

We obtain explicit consent from you prior to collecting, processing, or using your personal data, ensuring compliance with the updated standards through the following methods:

a) By clicking the “Next” button after agreeing to the PDPA declaration in our Learning Management System (LMS)

b) By ticking the checkbox after agreeing to the Magcolm’s privacy policy prior to placing an order on our WooCommerce online platform

c) By voluntarily filling in personal data such as company name, address, identity card number, name, contact information and etc in the online participant list, confirmation page for advisory and academy services.

3. PURPOSE OF DATA COLLECTION

Personal data may be collected, processed and used for purposes as follows:

a) Course registration, proposal submission, delivery of the services offered and the marketing of such services to you

b) Internal record management to meet authority requirement

c) Facilitate the payments for the services provided

d) Enable us to communicate or inform you any related information including our services, promotional and respond to your queries by the email or telecommunication means (telephone call or text messages)

e) To develop MAGCOLM’s business and services

f) To invite you to events organized by MAGCOLM

4. SPECIFIC DATA COLLECTION FOR E-LEARNING (MONITORING & PROCTORING)

To maintain the integrity of our E-Learning certifications, verify course completion and prevent unauthorized account sharing, Magcolm Solutions Sdn Bhd utilizes digital monitoring technologies and third-party tracking applications. By enrolling in and accessing our E-Learning platform, you expressly consent to the collection and processing of the following data:

a) Access Logs: The exact dates, times and IP addresses of your system logins.

b) Usage History: A record of specific course pages visited, files downloaded and the chronological order of your interactions with the content.

c) Device & Network Information: Your specific browser type (User Agent) and operating system. This is strictly monitored to detect multiple concurrent logins or potential account-sharing violations.

Purpose: This data is collected solely for the purposes of certification validation, dispute resolution regarding service delivery, and the enforcement of our intellectual property rights. We do not use this specific proctoring data for marketing purposes.

5. DATA SUBJECT RIGHTS

You have the following rights regarding your personal data:

a) The right to access your personal data

b) The right to request corrections to inaccurate or incomplete data

c) The right to object to the processing of your data for marketing purposes

d) The right to withdraw consent at any time, subject to legal restrictions

e) The right to data portability, allowing you to request that your data be transferred to another service provider

f) Enhanced rights concerning automated decision-making, where applicable

6. REFUSAL/FAILURE TO PROVIDE PERSONAL DATA

The personal data provided to Magcolm Solutions are completely voluntary in nature and you are not under any commitment or pressure to do so. However, we shall not be held for any liable upon failure to provide the personal data.

The failure to provide the personal data requested will result in:

a) Inability of parties to formalize any contract and/or agreement in relation to our sale of services

b) Inability to deliver our services, notices and respond your queries efficiently,

c) Inability to inform and update you with our latest services and promotion,

d) Inability to complete commercial transactions in relations to our projects, training courses and/or services

e) Inability to comply with any applicable law, authority, regulation, guidelines and/or codes applicable to us relate to SST, HRD Corp Claimable Corse Scheme, MOH Food Handler Course, e-invoice and etc

7. DISCLOSURE OF DATA

The company will be in full responsible to safe keep the collected information from you. We do not sell, rent, trade or lease any of your personal data stored in our database to third parties. However, we may disclose the collected personal information for the following purposes:

a) Disclosure of information to business partners and affiliates which involved in our business

b) In any circumstances where the disclosure is required for law purpose, to co-operate with law enforcement authorities, or to protect our rights, property or safety of the company and our customers

c) Related government agencies, statutory authorities and industry regulators

d) The third parties who perform services on our behalf, but in condition that the third parties uses the information only to perform the services as requested and agrees to maintain the information as strictly confidential

8. DATA PROTECTION OFFICER (DPO)

Magcolm Solutions Sdn Bhd has appointed Ms. Alicia Kho as the Data Protection Officer (DPO). The DPO is responsible for overseeing compliance with this policy and the relevant data protection laws. You can contact Ms. Alicia at:

• Email: alicia@magcolm.my
• Tel: 03 2789 7901

9. DATA BREACH NOTIFICATION

In the event of a data breach, the Managing Director and Managing Consultant are responsible for promptly notifying affected individuals and the relevant authorities as required by law. Notifications will detail the nature of the breach and any actions taken.

10. RETENTION PERIOD

The company will only retain the personal data within the period of we provide you with the services, to fulfil legal and regulatory requirements and internal company policy. The data will be permanently destroy or deleted after no longer required for the purpose of stated reason.

We will retain your personal data for the following minimum periods:

a) Physical copies of records will be kept for a minimum of 3 years for MOH and HRD Corp compliance

b) Soft copies of records will be retained for a maximum of 10 years for financial compliance

11. CROSS-BORDER DATA TRANSFERS

Any transfer of personal data outside Malaysia will comply with the relevant regulations and guidelines, ensuring that appropriate safeguards are in place to protect your data.

12. USE OF COOKIES AND TRACKING TECHNOLOGIES

Magcolm Solutions Sdn Bhd utilizes “cookies” (small text files placed on your device) and similar tracking technologies to enhance your user experience.

a) Strictly Necessary Cookies: Required for the operation of our LMS and WooCommerce shopping cart (e.g., keeping items in your cart while you browse).

b) Performance & Analytics Cookies: Used to track course progress, user engagement and system stability.

c) Functionality Cookies: Remember your login details and language preferences. You may choose to disable cookies through your browser settings; however, doing so may prevent you from accessing certain features of the E-Learning platform or completing a purchase.

13. LINKS TO THIRD-PARTY WEBSITES
Our website and LMS may contain links to external websites (e.g., HRD Corp, Ministry of Health or third-party payment gateways). This Privacy Policy applies solely to Magcolm Solutions Sdn Bhd. We are not responsible for the privacy practices or content of such external sites. We encourage you to read the privacy policies of any third-party sites you visit.

14. SECURITY MEASURES

Rest assured that your data is protected and keep in a secure manner. We take appropriate physical, electronical and managerial measures to safeguard the data collected to prevent any misused or unlawful processing of your personal data.

All of our staff are committed to practicing of clean desk policy during office hours in the office premise.

We implement appropriate physical, electronic and managerial measures to protect your personal data from unauthorized access, loss, or misuse. This includes regular security assessments and updates to our data protection practices.

15. PENALTIES AND ENFORCEMENT

Non-compliance with this policy may result in penalties as stipulated in the 2024 amendments to the Personal Data Protection Act. We are committed to ensuring compliance and will take necessary actions to enforce this policy.

16. REVIEW AND REVISION CLAUSE

This policy will be reviewed yearly to ensure compliance with the latest regulations and amendments. Revisions will be made as necessary to reflect changes in the law or our practices.

CONTACT INFORMATION

To exercise your rights or for any inquiries regarding this policy, please contact:

Magcolm Solutions Sdn Bhd

No. 3-1-6, Kompleks Kantonmen Prima,
Batu 4 ½, Jalan Ipoh, 51200 Kuala Lumpur.

Tel / Fax : 03 2789 7901

Email: alicia@magcolm.my

Date of Policy: 03 December 2025

Version: 3.0