Privacy Policy

1. Introduction

Centavo ("we", "us", "our") is committed to protecting the personal data of individuals who enquire about or participate in our educational programmes. This policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have in relation to your data.

This policy applies to data collected through our website at centavobn.world, via enquiry forms, by telephone and in connection with our programmes delivered at Level 20, Menara Public Bank, No. 146 Jalan Ampang, 50450 Kuala Lumpur.

Questions about this policy may be directed to [email protected].

2. Personal Data We Collect

We collect only the personal data necessary for the administration of our educational programmes and related communications. This includes:

• Identification data: full name
• Contact data: email address, telephone number (optional)
• Communication data: the content of enquiries or messages you send us
• Programme participation data: which programme(s) you have enrolled in and attendance records
• Technical data: IP address, browser type, pages visited, collected automatically when you use our website
• Cookie data: as described in our Cookie Policy

We collect this data when you submit an enquiry form, contact us by telephone or email, register for a programme, or browse our website.

Legal basis for processing: your consent (for marketing communications and non-essential cookies); the performance of a contract or pre-contractual steps (for programme administration); our legitimate interests (for website analytics and security); and compliance with legal obligations under Malaysian law, including the Personal Data Protection Act 2010 (PDPA).

3. How We Use Your Data

Your personal data is used for the following purposes:

• Responding to enquiries about our programmes
• Processing registrations and administering programme participation
• Sending session reminders, materials and related programme communications
• Sending information about future programmes or updates — only where you have opted in
• Improving our website and services through anonymised analytics
• Complying with applicable Malaysian legal obligations

We do not sell your personal data to third parties. We may share limited data with service providers who assist us with website hosting or email delivery, under data processing agreements that require them to protect your data.

Data retention: enquiry data is retained for 12 months if you do not enrol. Programme participation records are retained for three years following completion of a programme, after which they are securely deleted. You may request earlier deletion at any time (see Section 6).

4. Data Protection Measures

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

• Encrypted data transmission via HTTPS on our website
• Restricted access to personal data — only team members who need it for their role
• Secure storage of digital records with access controls
• Regular review of security practices

In the event of a data breach that is likely to result in a risk to individuals, we will take prompt steps to contain and assess the breach and will notify affected individuals and, where required, the relevant authorities under the PDPA.

5. Cookies

Our website uses cookies to function correctly and to help us understand how visitors use the site. Essential cookies are required for basic site operation and cannot be disabled. Other cookie categories (analytics, marketing, preferences) are optional and set only with your consent.

For full details of the cookies we use and how to manage your preferences, please see our Cookie Policy.

6. Your Rights Under the PDPA

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

• Access the personal data we hold about you
• Correct any personal data that is inaccurate or incomplete
• Withdraw consent to the processing of your personal data at any time (subject to our legitimate interests or legal obligations)
• Request erasure of your personal data in certain circumstances
• Object to direct marketing communications at any time
• Lodge a complaint with Malaysia's Department of Personal Data Protection (JPDP) if you believe your rights have not been upheld

To exercise any of these rights, please contact us at [email protected]. We will respond within 21 days.

7. Third-Party Links

Our website may contain links to external websites or resources. We are not responsible for the privacy practices of those sites. We encourage you to read the privacy policies of any external sites you visit.

8. Children's Privacy

Our programmes and website are intended for adults aged 18 and above. We do not knowingly collect personal data from anyone under 18. If you believe a minor has submitted data to us, please contact [email protected] and we will promptly delete it.

9. Updates to This Policy

We may update this policy from time to time to reflect changes in our practices or applicable law. The revised policy will be posted on this page with an updated date. Where changes are material, we will notify registered participants by email.