Privacy Policy

1. Introduction

Ashcombe Pelleas ("we", "us", "our") is committed to handling personal information with care and in accordance with the Personal Data Protection Act 2010 (PDPA) of Malaysia. This policy explains what information we collect, why we collect it, and how we use and protect it.

This policy applies to all personal information we receive through our website at ashcombe, our contact forms, and in the course of delivering our education programmes. Questions about this policy may be directed to privacy@ashcombe.

2. Data We Collect

We collect the following categories of personal information:

• Name and contact details (email address, phone number) when submitted via our enquiry form
• Correspondence records — messages sent to us by email or through our website
• Programme enrolment information — which programme you have enrolled in, payment records, and completion status
• Usage data — pages visited on our website, browser type, and visit duration (via analytics cookies, where consented)
• Preferences stored via cookie consent settings

We do not collect sensitive personal data such as identity card numbers, financial account details, or health information.

3. How We Use Personal Data

Your personal information is used only for the following purposes:

• Responding to enquiries submitted through our contact form
• Delivering the programme you have enrolled in — sending materials, access instructions, and facilitator correspondence
• Issuing completion records on programme completion
• Sending relevant programme updates or information about upcoming workshops, where you have indicated interest
• Improving the website and programmes through anonymised usage analysis
• Complying with our legal obligations under Malaysian law

We do not use your personal data to send unsolicited commercial marketing, and we do not sell or share it with third parties for marketing purposes.

4. Legal Basis for Processing

We process personal data on the following bases under the PDPA 2010:

• Your consent, given when you submit an enquiry form or accept cookies
• Contractual necessity, when you enrol in one of our programmes
• Legitimate interests, for the purpose of managing and improving our educational services
• Legal obligation, where applicable under Malaysian law

5. Data Retention

We retain personal data for the following periods:

• Enquiry records (without enrolment): 12 months from the date of enquiry
• Programme enrolment records: 5 years from programme completion, for administrative and record-keeping purposes
• Financial transaction records: 7 years, as required under Malaysian company law
• Marketing preference records: until withdrawn

After these periods, personal data is deleted or anonymised.

6. Data Protection Measures

We take the security of personal data seriously. Our measures include:

• Secure, encrypted transmission of data via HTTPS
• Access to personal data restricted to staff with a direct need in their role
• Regular review of data access and storage practices
• Third-party service providers who process data on our behalf are required to meet appropriate security standards

In the event of a data breach likely to cause harm, we will notify affected individuals and the relevant Malaysian authority in accordance with our obligations under PDPA 2010.

7. Cookies

We use cookies on our website to support basic functionality and, where consented, to understand how visitors use the site. Full details of the cookies we use and how to manage your preferences are set out in our Cookie Policy.

8. Third-Party Services

We use a small number of third-party services in operating our website and programmes. These may include website hosting, email delivery, and analytics. Where these services involve the processing of personal data, we require appropriate data processing agreements to be in place.

Links from our website to third-party websites are provided for convenience. We are not responsible for the privacy practices of those sites.

9. Your Rights

Under the Personal Data Protection Act 2010 (Malaysia), you have the following rights:

• Right to access — you may request a copy of the personal data we hold about you
• Right to correction — you may request correction of inaccurate or incomplete data
• Right to withdraw consent — you may withdraw consent to processing at any time, without affecting the lawfulness of prior processing
• Right to limit processing — in certain circumstances, you may request that we restrict how we use your data

To exercise any of these rights, contact us at privacy@ashcombe. We will respond within 21 days.

10. Children's Privacy

Our programmes are intended for adults aged 18 and above. We do not knowingly collect personal information from individuals under 18. If we become aware that we have done so, we will delete that information promptly.

11. Changes to This Policy

We may update this policy from time to time. Where changes are material, we will update the "Last Updated" date at the top of this page and, where appropriate, notify enrolled participants by email. Continued use of our website or programmes after changes take effect constitutes acceptance of the updated policy.