Privacy Policy
Last Updated: 15 May 2025
1. Introduction
Athwen ("we", "us", "our") is a business consulting firm registered and operating in Malaysia. We are committed to protecting the personal data of individuals who interact with our website and engage our services. This Privacy Policy explains what data we collect, how we use it, and the rights available to you.
This policy applies to personal data collected through our website at athwens.sbs, through our contact forms, and through the course of our consulting engagements.
For questions about this policy, contact us at [email protected].
2. Personal Data We Collect
We collect the following categories of personal data:
- Contact information — full name, email address, and phone number submitted via our contact form.
- Enquiry content — the text of messages you send us describing your project or service interest.
- Usage data — pages visited, time on site, and general browser information, collected via analytics cookies if you have consented.
- Engagement data — information relevant to the conduct of a consulting engagement, shared by you or your organisation during the course of that engagement.
Legal Basis for Processing
We process personal data under the Personal Data Protection Act 2010 (PDPA) of Malaysia. The legal bases we rely on are:
- Your consent, given when you submit a contact form or accept cookies
- Contractual necessity, when data is required to fulfil a consulting engagement
- Legitimate interests, for internal analysis of how our website is used
Data Retention
Enquiry data is retained for up to 24 months from the date of submission. Engagement-related data is retained for up to 7 years in accordance with standard Malaysian commercial record-keeping requirements. Analytics data is retained for up to 26 months.
3. How We Use Your Data
- To respond to enquiries and arrange introductory conversations
- To conduct and administer consulting engagements
- To send relevant service information, only where you have consented to receive it
- To analyse and improve the performance of our website using aggregated usage data
- To comply with applicable Malaysian legal and regulatory obligations
Third-Party Sharing
We do not sell personal data to third parties. We may share data with service providers who assist us in operating this website (such as analytics platforms), under agreements that require them to protect your data in accordance with applicable law. We do not share client engagement data with any external party without your explicit agreement.
4. Data Security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. These include:
- HTTPS encryption for all website communications
- Access controls limiting data access to authorised staff
- Periodic review of data handling practices
- Confidentiality agreements with all staff and contractors who handle personal data
In the event of a data breach that is likely to affect your rights, we will notify you and the relevant authority within the timeframes required by Malaysian law.
5. Cookies
Our website uses cookies to support basic functionality and, where you have consented, to understand how the site is used. We use essential cookies (always active), analytics cookies, and preference cookies. For full details and to manage your cookie preferences, please see our Cookie Policy.
6. Your Rights Under Malaysian Law
Under the Personal Data Protection Act 2010 (PDPA), you have the following rights in relation to your personal data:
Right of Access
You may request a copy of the personal data we hold about you.
Right to Correction
You may ask us to correct personal data that is inaccurate or incomplete.
Right to Withdraw Consent
Where processing is based on consent, you may withdraw that consent at any time.
Right to Prevent Processing
You may object to the processing of 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 are not satisfied with our response, you may contact the Department of Personal Data Protection Malaysia (JPDP).
7. Third-Party Links
Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and recommend that you review their privacy policies separately before providing any personal data.
8. Children's Privacy
Our services are intended for organisations and individuals aged 18 and above. We do not knowingly collect personal data from persons under the age of 18. If we become aware that we have collected data from a minor, we will delete it promptly.
9. Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will note the updated date at the top of this page. We encourage you to review this policy periodically. Continued use of our website after changes are published constitutes acceptance of the revised policy.