Privacy Policy
Kintsugi — Last updated: 22 April 2025
1. Introduction
Kintsugi ("we", "us", "our") is committed to protecting the personal data of individuals who interact with us — including programme enquirers, registered participants, and visitors to this website. This policy explains what data we collect, why we collect it, how we use it, and what rights you have.
We operate in Kuala Lumpur, Malaysia, and process personal data in accordance with the Personal Data Protection Act 2010 (PDPA 2010) of Malaysia. Questions about this policy can be sent to [email protected].
2. Data we collect
When you submit an enquiry or register for a programme
- Name
- Email address
- Phone number (if provided)
- Message content
- Programme of interest
When you visit this website
- IP address (via analytics tools, if consent is given)
- Browser type and device information
- Pages visited and session duration
- Referral source
During programme delivery
Session notes taken by coaching educators remain with the participant and are not retained by Kintsugi after the programme ends. Group workshop sessions do not collect individual financial data from participants.
3. Legal basis for processing
- Consent: When you submit a form on this website or accept cookies, you consent to the processing described in this policy.
- Contract: When you enrol in a programme, processing your contact and payment details is necessary to deliver the service.
- Legitimate interests: We may process data to maintain records of programme participants, manage communications, and improve our curriculum — where this does not override your rights.
4. How we use your data
- To respond to enquiries
- To register and communicate with programme participants
- To send information about upcoming sessions, dates, or relevant updates (where you have consented)
- To improve the website and programme content using aggregated analytics
- To comply with legal obligations under Malaysian law
We do not sell, rent, or trade your personal data to third parties. We do not use your data for advertising or share it with financial product providers.
5. Data sharing
We may share data with the following categories of service providers strictly to enable programme delivery:
- Email service providers (for communication)
- Payment processors (for programme fees)
- Video conferencing services (for online sessions, where applicable)
These providers process data only on our instructions and are required to maintain appropriate security measures.
6. Data retention
We retain enquiry data for up to 12 months from the date of last contact. Programme participant records are retained for 3 years for administrative purposes. Analytics data is retained in aggregated, anonymised form. You may request deletion of your data at any time (see Section 9).
7. Cookies
This website uses cookies. Essential cookies are required for basic site functionality. Analytics and preference cookies are only placed with your consent. You can manage your cookie preferences at any time via our Cookie Policy page.
8. Data security
We use reasonable technical and organisational measures to protect personal data from unauthorised access, disclosure, or loss. These include encrypted connections (HTTPS), access controls, and secure data storage. In the event of a data breach that may affect your rights, we will notify you as required under applicable law.
9. Your rights under PDPA 2010
Under Malaysia's Personal Data Protection Act 2010, you have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate data
- Request that we stop processing your data for direct marketing
- Withdraw consent at any time (without affecting processing already carried out)
- Request deletion of your data, subject to legal retention requirements
To exercise any of these rights, contact us at [email protected]. We will respond within 21 days.
10. Third-party links
This website may contain links to external sites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies independently.
11. Children
Our programmes are designed for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If you believe we have inadvertently done so, please contact us and we will delete the data promptly.
12. Changes to this policy
We may update this policy from time to time. The current version is always available on this page. Significant changes will be communicated to registered participants by email where practicable. Continued use of our services after a policy update constitutes acceptance of the revised terms.
13. Contact
Data controller: Kintsugi, Jalan Stonor 27, 50450 Kuala Lumpur, Malaysia.
Email: [email protected]
Phone: +60 3 2148 7396