Privacy Policy

1. Overview

ClickSmart Digital Technology Sdn. Bhd. (Company No. 202201045129 / 1490826-X) ("ClickSmart", "we", "us", or "our") is committed to protecting the personal data of our clients, prospective clients, website visitors, and training participants.

This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you visit our website at clicksmart.com.my, contact us, use our services, or participate in our training programmes.

This policy is prepared in compliance with the Personal Data Protection Act 2010 (PDPA), Malaysia. By using our website or services, you consent to the practices described in this policy.

2. Personal Data We Collect

We collect personal data that you voluntarily provide to us and data collected automatically when you use our website.

2.1 Data You Provide Directly

• Contact & Enquiry Data: Name, email address, phone number, company name, job title, and messages submitted via our contact form or email.
• Consultation Data: Business information, team size, operational challenges, and requirements shared during consultations.
• Training Registration Data: Name, NRIC/passport number, employer details, HRDC levy information, and training attendance records for HRDC-claimable programmes.
• Contract & Billing Data: Business registration details, signatory information, and payment records for service engagements.
• Communication Records: Emails, meeting notes, and correspondence relating to project delivery.

2.2 Data Collected Automatically

• Usage Data: Pages visited, time spent, referring URLs, browser type, device type, and operating system.
• Technical Data: IP address, browser identifiers, and session data collected via cookies and analytics tools.

3. How We Use Your Personal Data

We use your personal data for the following purposes:

• To respond to your enquiries and provide the digital transformation consultation or service you requested.
• To prepare proposals, service agreements, and project scopes of work.
• To deliver software implementation, training, and support services.
• To process HRDC levy claims for eligible training programmes.
• To send service-related communications, project updates, and support responses.
• To send marketing communications about our services, events, and resources — only with your consent or where permitted by law.
• To improve our website, services, and marketing based on usage analytics.
• To comply with our legal obligations under Malaysian law.
• To maintain internal business records and financial accounts.

4. Legal Basis for Processing

Under the PDPA 2010 (Malaysia), we process your personal data on the following grounds:

• Consent: Where you have given explicit consent to receive marketing communications or for specific data uses.
• Contract: Where processing is necessary to fulfil a service agreement or take pre-contractual steps at your request.
• Legal Obligation: Where we are required to process data to comply with applicable Malaysian laws, including HRDC regulatory requirements.
• Legitimate Interests: Where processing is necessary for our legitimate business interests (e.g. improving our services, fraud prevention) and does not override your rights.

5. Data Sharing & Disclosure

We do not sell your personal data to third parties. We may share your data with:

• Platform Partners: ClickUp, Lark Suite, and Meegle — strictly for the purpose of setting up and managing your digital workspace accounts.
• HRDC (Human Resources Development Corporation): For processing levy claims related to training programmes you participate in.
• Service Providers: Email hosting, analytics, and project management tools used to deliver our services (all bound by data processing agreements).
• Legal & Regulatory Authorities: Where required by Malaysian law, court order, or regulatory obligation.
• Business Successors: In the event of a company merger, acquisition, or sale of assets, subject to equivalent data protection obligations.

All third-party service providers are contractually required to handle your data securely and only for specified purposes.

6. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes described in this policy, or as required by Malaysian law:

• Client project records: 7 years from project completion (as required under Malaysian financial and commercial law).
• HRDC training records: As required by HRDC regulations (minimum 3 years).
• Marketing enquiry data: 2 years from last interaction, or until you withdraw consent.
• Website analytics: 13 months (aggregated, not personally identifiable after this period).

When data is no longer required, we securely delete or anonymise it.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction, including:

• HTTPS encryption for all website traffic.
• Access controls limiting data to authorised personnel only.
• Secure cloud storage with reputable, compliance-certified providers.
• Regular security reviews and staff training on data protection.

While we take all reasonable precautions, no transmission over the internet or electronic storage is 100% secure. If you believe your data has been compromised, contact us immediately at hello@clicksmart.com.my.

8. Your Rights Under PDPA 2010

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

• Right of Access: You may request a copy of the personal data we hold about you.
• Right of Correction: You may request correction of inaccurate or incomplete personal data.
• Right to Withdraw Consent: You may withdraw consent for marketing communications at any time by emailing us or clicking "unsubscribe" in any marketing email.
• Right to Limit Processing: You may request that we restrict the processing of your personal data in certain circumstances.

To exercise any of these rights, contact us at hello@clicksmart.com.my. We will respond within 21 days as required by PDPA 2010. Requests to access data may be subject to a fee as permitted under the Act.

9. Cookies & Tracking

Our website uses cookies to enhance your browsing experience and analyse traffic. Cookies are small text files stored on your device.

9.1 Types of Cookies We Use

• Essential Cookies: Necessary for the website to function. Cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our site (e.g. Google Analytics). These are anonymised and aggregated.
• Marketing Cookies: Used to deliver relevant advertisements. Only enabled with your consent.

You can manage or disable cookies through your browser settings. Disabling essential cookies may affect website functionality. For more information, visit allaboutcookies.org.

10. Third-Party Links

Our website may contain links to third-party websites including ClickUp, Lark, and Meegle. Once you leave our website, this Privacy Policy no longer applies. We recommend reading the privacy policies of any third-party websites you visit. ClickSmart is not responsible for the privacy practices of external websites.

11. Children's Privacy

Our services are intended for business professionals and organisations. We do not knowingly collect personal data from individuals under 18 years of age. If you believe we have inadvertently collected data from a minor, please contact us immediately and we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will:

• Update the "Last updated" date at the top of this page.
• Notify active clients by email for significant changes.
• Post a notice on our website homepage for 30 days.

Continued use of our website or services after changes constitute your acceptance of the updated policy.

13. Contact Us About This Policy

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact our Data Protection Officer:

If you are not satisfied with our response, you have the right to lodge a complaint with the Personal Data Protection Department (JPDP), Malaysia at www.pdp.gov.my.