Introduction
Glasswing ("we", "our", "us") operates as a business process documentation advisory firm registered in Malaysia. We are the data controller for personal information processed through this website and in connection with our services.
This policy applies to all personal data collected through our website at {{DOMAIN}}, through enquiry forms, email correspondence, and through the delivery of our documentation advisory services.
We process personal data in accordance with the Personal Data Protection Act 2010 (PDPA) of Malaysia. By using our website or engaging our services, you acknowledge that your data may be processed as described here.
Data We Collect
Information you provide directly
- Full name and organisation name
- Email address and telephone number
- Message content submitted through our enquiry form
- Any additional information shared during service engagements
Information collected automatically
- Browser type, operating system, and device information
- IP address and approximate location
- Pages visited, time spent, and navigation paths
- Referring website or search terms
Legal basis for processing
- Consent — for marketing communications and non-essential cookies
- Contractual necessity — to deliver services you have engaged
- Legitimate interest — to improve our website and respond to enquiries
- Legal obligation — where required by Malaysian law
Retention periods
- Enquiry and contact data: 2 years from last contact
- Client engagement records: 7 years for accounting and compliance purposes
- Website analytics data: 26 months
- Cookie consent records: 12 months
How We Use Your Data
Service delivery and communication
- Responding to your enquiries and scheduling consultations
- Delivering process documentation advisory services
- Sharing session materials, documents, and templates
- Sending service-related updates and follow-ups
Website improvement and analytics
- Understanding how visitors navigate and use the site
- Identifying content that is most useful to our audience
- Diagnosing technical issues and maintaining site performance
Data sharing
We do not sell personal data. We may share data with:
- Analytics providers (e.g., Google Analytics) to understand site usage — data is anonymised where possible
- Email and calendar tools used to coordinate service delivery — subject to their own privacy policies
- Legal or regulatory authorities if required under Malaysian law
Marketing communications
We only send marketing communications where you have provided consent. Each message includes a clear way to opt out. We do not share your contact details with third parties for their own marketing purposes.
Data Protection Measures
Security practices
- Website communications are encrypted using TLS/HTTPS
- Access to personal data is restricted to authorised personnel only
- Third-party processors are assessed for data security standards before engagement
- Data stored in cloud systems is subject to their respective security frameworks
Breach response
In the event of a data breach that poses a risk to affected individuals, we will notify the relevant parties as required under the PDPA 2010 and take prompt steps to contain and assess the incident.
Limitations
While we take reasonable steps to protect your data, no transmission over the internet is fully secure. We encourage you not to share sensitive information through unencrypted channels.
Cookies
Our website uses cookies and similar technologies to support site functionality and to understand usage patterns. Cookies are small text files placed on your device when you visit the site.
- Essential cookies — required for basic site operation; always active
- Analytics cookies — used to understand how the site is used; optional
- Preference cookies — used to remember settings you have chosen; optional
- Marketing cookies — used for relevant communications; optional
You can manage your cookie preferences at any time through our Cookie Policy page, which provides full details and interactive controls.
Your Rights
Under the PDPA 2010, you have the following rights in relation to your personal data:
Access
Request a copy of the personal data we hold about you.
Correction
Request corrections to inaccurate or incomplete data.
Withdrawal of consent
Withdraw consent for marketing or non-essential data uses at any time.
Objection
Object to processing based on legitimate interest in certain circumstances.
Restriction
Ask us to limit how we process your data while a concern is being reviewed.
Complaint
Lodge a complaint with the Personal Data Protection Commissioner of Malaysia.
To exercise any of these rights, please write to privacy@{{DOMAIN}}. We aim to respond within 21 working days.
Third-Party Links
Our website may include links to external websites for reference or informational purposes. We are not responsible for the privacy practices of those sites and encourage you to review their policies before submitting any personal information.
Embedded content such as maps may be served by third-party platforms (e.g., Google Maps). These services operate under their own privacy policies.
Children's Privacy
Our services are directed at businesses and professional individuals. We do not knowingly collect personal data from anyone under 18 years of age. If we become aware that personal data has been submitted by a minor, we will remove it promptly.
Policy Updates
We may update this policy from time to time to reflect changes in our practices or in applicable law. The revised policy will be published at this address with an updated date at the top.
Where changes are material, we will take reasonable steps to bring them to your attention, such as by placing a notice on our website. Continued use of the site after updates are published constitutes acceptance of the revised policy.
Contact for Data Enquiries
If you have questions about this policy, wish to exercise your rights, or have concerns about how your data is handled, please reach out through any of the following:
Data Controller: Glasswing · Personal Data Protection Commissioner Malaysia (PDPC) for supervisory authority complaints.