Privacy Policy
Last updated: 10 June 2025 · Verdantia · George Town, Penang, Malaysia
1. Introduction
Verdantia ("we", "us", "our") is committed to handling personal data with care. This policy describes what data we collect from you, how we use it, how long we keep it, and what your rights are in relation to it. It applies to personal data collected through our website, through session registrations, and through any clerical or archival engagement we carry out.
This policy is written in accordance with Malaysia's Personal Data Protection Act 2010 (Act 709). If you have questions about how we handle your data, please contact us at [email protected].
The data controller for the purposes of this policy is Verdantia, located at 26 Jalan Macalister, 10400 George Town, Pulau Pinang, Malaysia.
2. Data We Collect
We collect the following personal data in the circumstances described:
- Contact enquiries: Name, email address, and telephone number (where provided) submitted through the contact form or by email.
- Session registrations: Name, email address, and telephone number used to confirm a place at a monthly session.
- Engagement records: For Document Locator, Index Build, and Multi-Household Coordination engagements, we collect the names of participating family members, the address of each participating household, and descriptions of documents — as recorded by the coordinator during visits. No document content is interpreted or stored beyond what is required to produce the index.
- Website analytics: Anonymised usage data (pages visited, session duration) where analytics cookies are accepted. No personally identifiable information is held in analytics data.
We do not collect sensitive personal data (as defined by PDPA 2010), financial account information, or medical information.
3. Legal Basis for Processing
- Consent: Where you submit a contact form or register for a session, you are consenting to us using your contact details to respond to your enquiry or confirm your registration.
- Contract: Where an engagement letter is signed, we process personal data as necessary to carry out the agreed scope of work.
- Legitimate interest: We may retain anonymised records of session attendance numbers for internal planning purposes.
4. How We Use Personal Data
- To respond to enquiries sent through the website or by email
- To confirm session registrations and send joining details
- To carry out the agreed scope of any signed engagement
- To produce and deliver the index, booklet, or custody agreement specified in an engagement letter
- To send a deletion confirmation at the close of an engagement
- To comply with any legal obligation that requires us to retain records
We do not use personal data for marketing without explicit consent. We do not sell personal data to any third party.
5. Data Retention
- Contact enquiries: Retained for six months following the last communication, then deleted.
- Session registrations: Retained for 30 days after the session date, then deleted.
- Engagement records: Retained for the duration of the engagement. Digital copies produced for the family are deleted from Verdantia's systems at the close of the engagement, and deletion is confirmed in writing. Anonymised records of engagement type and duration are retained for internal planning for up to 24 months.
- Analytics data: Anonymised; retained for 12 months, then deleted.
6. Data Protection Measures
We take reasonable technical and organisational steps to protect personal data from unauthorised access, loss, or disclosure:
- Digital copies produced during engagements are stored in password-protected, encrypted archives while held on our systems
- Access to personal data held on our systems is limited to the coordinator assigned to the relevant engagement
- Physical records are stored in a locked office at 26 Jalan Macalister, George Town
- In the event of a data breach that is likely to result in harm to you, we will notify you without undue delay and, where required, notify the relevant supervisory authority
7. Cookies
Our website uses cookies. Essential cookies are required for the site to function. Optional analytics and preference cookies are used only where you have given consent via the cookie banner on our homepage. For a full explanation of the cookies we use and how to manage your preferences, please see our Cookie Policy.
8. Third Parties
We do not share personal data with third parties except in the following circumstances:
- Where required by law or by a competent authority in Malaysia
- Where you have explicitly asked us to refer your details to a professional in the referral directory — in this case, we share only the information you ask us to pass on, and only to the professional you have identified
- To analytics service providers operating under data processing agreements that prohibit them from using your data for their own purposes
Our website may contain links to external websites. Verdantia is not responsible for the privacy practices of those sites. We encourage you to read their privacy policies before submitting personal data.
9. Your Rights
Under the Personal Data Protection Act 2010 (Act 709), you have the following rights in relation to your personal data held by Verdantia:
- Right of access: You may request a copy of the personal data we hold about you.
- Right of correction: You may ask us to correct inaccurate data.
- Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
- Right to limit processing: You may ask us to stop processing your data for purposes other than those strictly necessary to carry out a signed engagement.
- Right to make a complaint: You may lodge a complaint with the Personal Data Protection Department of Malaysia (Jabatan Perlindungan Data Peribadi, pdp.gov.my).
To exercise any of the above rights, write to us at [email protected]. We will respond within 21 days.
10. Children
Our services are intended for adults (18 years and above). We do not knowingly collect personal data from individuals under the age of 18. If you believe we have inadvertently collected such data, please contact us at [email protected] and we will delete it promptly.
11. Changes to This Policy
We may update this policy from time to time. The revised version will be posted on this page with an updated date. If changes materially affect how we process data collected under an active engagement, we will notify the relevant parties by email. Continued use of the website after the updated policy is posted constitutes acceptance of the changes.
12. Contact for Data Enquiries
For any question about this policy or the personal data Verdantia holds:
- [email protected]
- 26 Jalan Macalister, 10400 George Town, Pulau Pinang, Malaysia