Privacy Policy — pivotgraina

pivotgraina ("we", "us", "our") is committed to handling personal information responsibly and in accordance with the Personal Data Protection Act 2010 (PDPA) of Malaysia. This policy explains what personal data we collect, how we use it, and what rights you have regarding your information.

This policy applies to personal data collected through our website at pivotgrainax.com, through enquiry forms, and in the course of delivering advisory services. If you have questions, please contact us at [email protected].

1. Data We Collect

We collect personal data in the following ways:

Enquiry forms: Name, email address, and optionally phone number and a message. This is the primary way we receive personal data from prospective clients.
Email and phone correspondence: When you contact us directly, we retain the information shared in those communications.
Service delivery: During advisory engagements, we may receive business and personal information relevant to the work, including organisational documents, financial summaries, and team details provided voluntarily.
Website analytics: If you consent, anonymised usage data is collected to help us understand how the website is used.

2. How We Use Your Data

We use personal data for the following purposes:

Responding to enquiries and following up on consultation requests
Delivering the advisory services you have engaged us for
Sending relevant information about pivotgraina's services where you have expressed interest
Improving our website based on anonymised usage data
Complying with legal obligations under Malaysian law

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

3. Legal Basis for Processing

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

Consent: When you submit an enquiry form or subscribe to communications, you consent to us processing your data for those purposes. Consent may be withdrawn at any time.
Contractual necessity: During an active advisory engagement, processing is necessary to deliver the services agreed.
Legitimate interests: We may process data for purposes such as improving our services and responding to unsolicited enquiries where there is a reasonable expectation that we would do so.

4. Data Retention

We retain personal data only for as long as necessary:

Enquiry data: Up to 12 months if no engagement follows, or until you request deletion
Client engagement data: Up to 3 years after the engagement concludes, for reference and legal compliance purposes
Financial records: As required by Malaysian law (typically 7 years)

5. Data Sharing

We do not share personal data with third parties except in the following limited circumstances:

Service providers who assist us in operating our website or communications (e.g., email hosting), bound by confidentiality agreements
Where required by Malaysian law or a valid legal process
With your explicit consent for any other purpose

We do not share client information between clients or disclose engagement details to external parties.

6. Data Protection Measures

We take reasonable measures to protect personal data from unauthorised access, use, or disclosure:

Website traffic is encrypted via HTTPS
Client documents are stored in access-controlled systems
Team members are informed of their confidentiality obligations
We review our data handling practices periodically

In the event of a data breach that is likely to affect your rights or interests, we will notify you as soon as reasonably practicable.

7. Cookies

Our website uses cookies to support site functionality and, with your consent, to collect anonymised analytics data. You may manage your cookie preferences at any time. See our Cookie Policy for full details.

8. Your Rights Under PDPA

Under Malaysia's Personal Data Protection Act 2010, you have the following rights regarding your personal data:

Right of access: You may request a copy of the personal data we hold about you.
Right to correction: You may request that inaccurate or incomplete data be corrected.
Right to withdraw consent: You may withdraw consent to processing at any time, without affecting the lawfulness of prior processing.
Right to cease processing: You may request that we stop using your data for direct marketing purposes.

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

If you have a concern about our data practices, you may contact the Department of Personal Data Protection Malaysia (JPDP) at pdp.gov.my.

9. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and recommend reviewing their policies independently.

10. Children's Privacy

Our services are directed at business owners and managers. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted data to us, please contact us and we will delete it promptly.

11. Changes to This Policy

We may update this policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. Continued use of our website or services after an update constitutes acceptance of the revised policy. For material changes, we will notify active clients directly.

12. Contact

For privacy-related questions or requests:

Email: [email protected]
Address: pivotgraina, Lot 15-2, Wisma UOA Damansara II, Jalan Dungun, 50490 Kuala Lumpur, Malaysia