1. About This Policy
Foxglen ("we", "us", "our") is committed to handling personal data responsibly and in a manner consistent with the Personal Data Protection Act 2010 (Malaysia) ("PDPA"). This policy describes the types of personal data we collect, the purposes for which we use it, and the rights available to individuals whose data we hold.
This policy applies to information collected through our website at {{DOMAIN}}, through our contact forms, and through any direct communication you have with us.
2. Data Controller
The data controller responsible for the personal data described in this policy is:
Foxglen
Level 20, Menara Multi-Purpose, Capital Square
Jalan Munshi Abdullah, 50100 Kuala Lumpur
3. Personal Data We Collect
We collect only the personal data that is reasonably necessary for the purposes described below. This may include:
- Your name and the name of your organisation
- Your contact details, including email address and telephone number
- The content of messages you send us through our contact form or by email
- Basic information about your browser and device, collected through standard web server logs
- Cookie identifiers, where you have given consent for their use
We do not knowingly collect sensitive personal data as defined under the PDPA unless it is provided voluntarily and with your explicit agreement.
4. Purposes of Processing
We use your personal data for the following purposes:
- Responding to enquiries submitted through our contact form or sent directly to us
- Providing advisory services that you have engaged us to deliver
- Scheduling and managing sessions, communications, and deliverables
- Maintaining records of advisory engagements for administrative purposes
- Improving the usability and content of our website, where analytics are enabled
- Complying with legal obligations applicable to our business in Malaysia
We do not use your personal data for direct marketing without your consent.
5. Legal Basis for Processing
We process personal data on the following grounds:
- Consent — where you have given clear consent, such as when submitting a contact form or accepting cookies
- Contractual necessity — where processing is needed to fulfil an advisory engagement you have requested
- Legitimate interests — where processing is reasonably necessary for our business operations, provided this does not override your rights
- Legal obligation — where we are required to retain or process data under applicable Malaysian law
6. How We Share Your Data
We do not sell personal data to third parties. We may share personal data in the following limited circumstances:
- With service providers who support our operations, such as email platforms or document tools, under appropriate data processing agreements
- Where disclosure is required by Malaysian law, a court order, or regulatory authority
- With your consent, in cases where we engage a specialist or co-adviser as part of your engagement
Any third parties engaged in connection with our services are required to handle personal data with equivalent care and in compliance with applicable law.
7. Data Retention
We retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable Malaysian law and professional obligations. In practice:
- Enquiries that do not lead to an engagement are held for up to 12 months
- Records relating to completed advisory engagements are retained for up to 7 years
- Website usage logs are retained for up to 3 months
After these periods, data is deleted or anonymised in a secure manner.
8. Your Rights
Under the PDPA and where applicable, you have the right to:
- Request access to the personal data we hold about you
- Request correction of inaccurate or incomplete personal data
- Withdraw consent for processing, where consent was the basis for collection
- Request that we limit or cease processing your data in certain circumstances
To exercise any of these rights, please contact us using the details in Section 2. We will respond to requests within a reasonable time and in accordance with the PDPA.
9. Cookies
Our website uses cookies to help us understand how visitors use the site and to retain your preferences across visits. A cookie banner is displayed on your first visit, allowing you to accept or decline non-essential cookies. For a full description of the cookies we use, please see our Cookie Policy.
10. Security
We take reasonable technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or loss. Our website uses HTTPS encryption, and access to personal data within our organisation is restricted to those with a genuine need.
No method of data transmission over the internet is entirely secure. While we take care to protect your information, we cannot guarantee absolute security and encourage you to take care when sharing personal information online.
11. Changes to This Policy
We may update this policy from time to time to reflect changes in our practices or in applicable law. The "last updated" date at the top of this page will be revised accordingly. We encourage you to review this page periodically.
12. Contact Us
If you have questions about this policy or about the way we handle your personal data, please reach out to us:
You may also write to us at Level 20, Menara Multi-Purpose, Capital Square, Jalan Munshi Abdullah, 50100 Kuala Lumpur.