Privacy Policy

1. Data We Collect

We collect the following categories of personal data:

• Contact data: Name, email address, and phone number submitted through the enquiry form on this website.
• Enrolment data: Employer name, job title, and course selection provided during the enrolment process.
• Communication records: Correspondence by email or in person related to programme enquiries, enrolment, and feedback.
• Usage data: Pages visited, time on site, and browser type, collected via cookies and analytics tools. See our Cookie Policy for detail.

We do not collect payment card data directly. Payments are processed through a third-party payment provider; their privacy policy applies to that transaction.

2. Legal Basis for Processing

We process personal data on the following grounds, consistent with Malaysia's Personal Data Protection Act 2010 (PDPA):

• Contractual necessity: Processing required to deliver a course or consulting engagement you have enrolled in.
• Consent: Processing based on your agreement, such as analytics cookies and marketing communications. You may withdraw consent at any time.
• Legitimate interest: Processing needed for routine business operations such as responding to enquiries, maintaining records, and improving programme materials.
• Legal obligation: Processing required to comply with applicable Malaysian law.

3. How We Use Personal Data

• To respond to enquiries and confirm enrolment in programmes.
• To deliver course materials, maintain attendance records, and issue completion documentation.
• To conduct the discovery, review, and training components of consulting engagements.
• To send programme-related communications, including intake dates and schedule changes.
• To analyse website usage and improve site content. Analytics data is processed in aggregate where possible.
• To meet legal and regulatory requirements applicable in Malaysia.

We do not use personal data to send unsolicited marketing communications unless you have given explicit consent. You may opt out of marketing emails at any time by contacting [email protected].

4. Retention

• Enquiry data (no enrolment): Retained for six months from the date of last contact, then deleted.
• Enrolment and course records: Retained for the duration of the programme plus twelve months, then deleted unless legal requirements require longer retention.
• Consulting engagement records: Retained for the duration of the engagement plus twenty-four months.
• Analytics data: Retained for twelve months then aggregated or deleted.

5. Data Sharing

We do not sell personal data. We share data only in the following circumstances:

• Service providers: We use third-party tools for email delivery, website analytics, and payment processing. These providers process data only as needed to perform those functions and are bound by data processing agreements.
• HRD Corp claims: If you request HRD Corp reimbursement, we provide the information required to process your claim to HRD Corp.
• Legal requirements: We may disclose data if required to do so by Malaysian law, court order, or lawful request by a public authority.

6. Data Protection Measures

• This website is served over HTTPS. Data transmitted via the contact form is encrypted in transit.
• Access to personal data records is restricted to Cogniva staff who require it to carry out their role.
• Physical records are held in locked storage at the George Town premises.
• In the event of a data breach likely to affect your rights, we will notify affected individuals within 72 hours of becoming aware of it, to the extent required by applicable law.

7. Cookies

This website uses cookies for session management and analytics. You can manage your cookie preferences at any time. Full details are in our Cookie Policy.

8. Your Rights

Under Malaysia's Personal Data Protection Act 2010, you have the following rights regarding your personal data:

• Access: You may request a copy of the personal data we hold about you.
• Correction: You may request that inaccurate data be corrected.
• Withdrawal of consent: Where processing is based on consent, you may withdraw it at any time. This does not affect processing carried out before the withdrawal.
• Objection: You may object to processing based on legitimate interest where your circumstances warrant it.
• Erasure: You may request deletion of your personal data where no legal basis for retention exists.
• Complaints: You may lodge a complaint with the Personal Data Protection Department of Malaysia (JPDP) at pdp.gov.my if you consider that your rights have not been met.

To exercise any of these rights, contact [email protected]. We will respond within 21 days.

9. Third-Party Links

This website may link to external sites, including published research papers and regulatory resources. Cogniva is not responsible for the privacy practices of those sites. We recommend reading the privacy policy of any external site you visit.

10. Children

Cogniva's programmes are for individuals aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we become aware that we hold such data, we will delete it.

11. Changes to This Policy

If we make material changes to this policy, we will update the "Last Updated" date at the top of this page and, where appropriate, notify enrolled participants by email. Continued use of the website or our services after a policy change constitutes acceptance of the revised terms.