ShangZhan Academy Privacy Notice

1. Personal Data We May Collect

Depending on the nature of your enquiry, training arrangement or relationship with us, we may collect personal data such as:

• name;
• company name, company address and business details;
• job role or position;
• telephone number and email address;
• company location;
• training topic, requirements, preferred dates, delivery preferences and participant numbers;
• participant, registration, attendance and training-related information;
• identification, employer, grant, claim or HRD Corp-related information where required for an agreed training arrangement;
• communications with us through WhatsApp, email, telephone or other channels;
• quotation, invoice, payment or transaction-related information;
• files, materials, work samples or other information submitted for an enquiry, training activity or agreed service;
• photographs, video, audio or voice recordings where created or provided in connection with training;
• feedback, testimonials or reviews where provided; and
• technical website information when optional analytics is activated with your consent, including page paths, controlled interaction events, browser-, device- and network-related technical information, and analytics identifiers or cookies.

Please do not provide personal data that is not reasonably necessary for your enquiry or the relevant training arrangement.

Where certain personal data is reasonably required for an enquiry, quotation, booking, participant registration, HRD Corp administration, invoicing or another requested service, failure to provide that information may prevent or delay us from providing the relevant service or completing the requested arrangement.

2. How We Collect Personal Data

We may collect personal data when you:

• visit our website or submit a training enquiry;
• contact us through WhatsApp, email, telephone or another communication channel;
• request a quotation, make a booking or enter into a training arrangement;
• provide participant, attendance, HRD Corp or administrative information;
• attend, participate in or communicate with us during a training programme;
• provide files, materials, feedback, testimonials, photographs, recordings or other content; or
• are identified by an authorised client representative as a participant or contact person for an agreed training arrangement.

Where personal data is not collected directly from you, it may be provided by your employer, client organisation, authorised representative or another party involved in the relevant training arrangement.

3. How We Use Personal Data

We may use personal data, where appropriate and permitted by applicable law, to:

• respond to enquiries and discuss training requirements;
• prepare quotations, proposals, invoices and booking documentation;
• arrange, administer and deliver training programmes;
• communicate before, during and after training;
• manage participant registration, attendance and training records;
• provide agreed HRD Corp-related administrative support and supporting documentation;
• provide customer service and respond to questions, feedback or requests;
• maintain accounting, operational and business records;
• protect the security and integrity of our services;
• prevent or address misuse, fraud, disputes or legal matters;
• comply with applicable legal, regulatory, administrative, accounting or record-keeping requirements; and
• measure and improve website usage and performance where optional analytics has been activated with your consent.

We do not use personal data for unrelated purposes without an appropriate basis or notice.

4. WhatsApp, Email and Other Communications

If you choose to contact us through WhatsApp, email, telephone or another third-party communication service, the information you provide may also be handled by that service under its own terms and privacy practices.

The website enquiry form is designed to keep entered details in your browser until you choose to continue to WhatsApp. When you choose that action, the generated enquiry message is transferred to WhatsApp.

5. Training Administration, HRD Corp and Business Records

For an agreed training arrangement, we may use relevant company, participant, registration, attendance, supporting-document and administrative information to manage the programme and related business records.

Where HRD Corp-related administration or claim support is requested or applicable, we may use and provide relevant information and documents for that purpose.

HRD Corp approval, employer eligibility, programme status, claimability, reimbursement and payment remain subject to applicable requirements and decisions.

6. Photography, Recordings and Training Documentation

Training documentation and operational records are different from marketing or promotional use.

We may create or receive photographs, videos, audio recordings or other training documentation where appropriate for:

• an agreed training activity;
• programme administration;
• attendance or training records;
• operational purposes; or
• a client-requested arrangement.

Any recording of training content remains subject to the applicable Terms & Conditions, participant-privacy requirements and any agreed recording conditions.

7. Testimonials and Promotional Use

Registration, attendance or the provision of client or participant materials does not automatically give ShangZhan Academy permission to use identifiable personal data for marketing.

Where promotional use involves identifiable personal data, including a person’s face, name, voice, testimonial or contact information, the applicable Privacy Notice and any relevant media-consent or other appropriate permission process apply.

Where permission applies, relevant material may be used for ShangZhan Academy’s own portfolio, website, social-media channels, marketing or promotional communications.

A valid withdrawal or objection will be handled in accordance with the applicable permission, Privacy Notice, Terms & Conditions and legal requirements. Withdrawal does not necessarily require the recall of printed materials already distributed or guarantee the removal of screenshots, shares, caches or copies outside ShangZhan Academy’s reasonable control.

8. Participant-Created Work

Participant-created work remains subject to the ShangZhan Academy Terms & Conditions.

Unless the relevant client or participant opts out, and provided that the person giving permission has the necessary right or authority, ShangZhan Academy may feature selected participant-created work for its own portfolio, website, social-media channels, marketing and promotional communications.

This permission:

• is non-exclusive;
• is limited to ShangZhan Academy’s own marketing and promotional purposes;
• does not transfer ownership;
• does not permit ShangZhan Academy to sell the work as a standalone product; and
• does not permit unrestricted use by unrelated third parties.

Where participant-created work contains identifiable personal data, the applicable privacy and permission requirements also apply.

9. Sharing Personal Data

We may share relevant personal data only where reasonably necessary with categories of recipients such as:

• service providers that support email, hosting, cloud storage, productivity, communication, training delivery, design, video or content services;
• online meeting, training or collaboration platforms used for an agreed programme;
• HRD Corp, government bodies, regulators or other authorities where required or applicable;
• professional advisers, insurers, auditors or other service providers supporting our business;
• clients or authorised client representatives involved in an agreed training arrangement; and
• other parties where disclosure is required or permitted by applicable law or reasonably necessary to protect rights, safety or legitimate business interests.

We do not sell personal data as a standalone product.

10. International Processing

Some technology and service providers we use may process or store information outside Malaysia.

Where this occurs, we will handle the relevant personal data in accordance with applicable legal requirements and take appropriate safeguards where required.

11. Retention

We retain personal data for as long as reasonably necessary for the purposes described in this Privacy Notice, including to:

• manage enquiries and training arrangements;
• maintain accounting and business records;
• support HRD Corp-related administration where applicable;
• comply with legal, regulatory or administrative requirements;
• manage disputes; and
• meet legitimate operational needs.

The appropriate retention period may vary depending on the type of information, the relevant training arrangement, applicable requirements and the reason the information was collected.

12. Security

We take reasonable steps appropriate to the nature of the personal data and our activities to help protect personal data against unauthorised access, use, disclosure, alteration or loss.

No method of transmission, storage or communication is completely secure.

13. Your Privacy Requests and Choices

Subject to applicable law, you may contact us to:

• ask whether we hold personal data about you;
• request access to relevant personal data;
• request correction of inaccurate or incomplete information;
• request the transfer of your personal data to another data controller where the applicable legal requirements, technical feasibility and data-format compatibility are satisfied;
• withdraw consent where processing depends on consent;
• object to or seek to prevent certain processing where applicable;
• exercise applicable choices concerning direct marketing; or
• raise a privacy concern.

A request does not necessarily result in automatic deletion or cessation of all processing. We may need to retain or use information for legitimate business, legal, accounting, HRD Corp, regulatory, dispute-related or other applicable purposes.

We may request reasonable information to verify your identity, understand the request and protect personal data from unauthorised access or disclosure.

14. Website Analytics and Similar Technologies

Where optional analytics is enabled, ShangZhan Academy uses Google Analytics to help us understand website usage and performance. Google Analytics is activated only after you choose to allow analytics.

When activated with consent, Google Analytics may process page paths, controlled interaction events, browser-, device- and network-related technical information, and analytics identifiers or cookies to help us understand website usage and performance. Google acts as an analytics service provider and may process relevant information outside Malaysia in accordance with its applicable terms and privacy practices.

We do not send enquiry-form contents, names, email addresses, telephone numbers, company names, WhatsApp messages, prefilled WhatsApp links or other direct identifying information to Google Analytics. Advertising storage, Google Signals, advertising personalization and Google Ads linking are disabled for this implementation.

When Google Analytics is activated, user- and event-level data retention will be configured for 14 months, subject to Google's operation of standard aggregated reports and applicable deletion controls.

Your analytics choice is stored in your browser for six months. You can accept or reject optional analytics and later change your choice through Privacy Choices in the website footer. Withdrawing analytics consent stops future optional analytics collection through this website, subject to the handling of information already processed before withdrawal.

15. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our services, business practices, legal requirements or technology.

The latest version will be published on this website.

16. Contact Us

Privacy questions and requests may be sent to:

Y&K Vorteil Trading, trading as ShangZhan Academy Alor Setar, Kedah, Malaysia Email: admin@shangzhan.com.my