Privacy Policy
Last Updated: 10 July 2025 · Effective Date: 10 July 2025
This policy explains how Sparsemind ("we", "us", "our"), operating from 55 Jalan Harimau, Taman Century, 80250 Johor Bahru, Johor, Malaysia, collects, uses and protects personal data in connection with our online AI development programmes. It applies to all visitors to our website and to all enrolled participants.
1. Data We Collect
We collect the following categories of personal data:
- Contact data: Name, email address and, where provided, phone number — submitted through the enquiry or enrolment form on this website.
- Programme data: Submitted notebooks, audit reports and project deliverables that you provide as part of your enrolled programme.
- Communication data: Messages sent to us via email or through forum posts within the programme platform.
- Technical data: IP address, browser type, pages visited and session duration, collected automatically via server logs and, where consent is given, analytics cookies.
- Payment data: Where payment is processed, we collect the information necessary to complete the transaction. Payment card details are handled by our payment processor and are not stored by us.
2. Legal Basis for Processing
We process personal data under the following legal bases, consistent with the Personal Data Protection Act 2010 (PDPA) of Malaysia:
- Contractual necessity: To administer your enrolment, deliver programme materials, process payments and issue completion records.
- Legitimate interest: To respond to enquiries, maintain forum access, improve our programmes and detect misuse.
- Consent: For optional analytics and marketing cookies, and for any direct marketing communications. You may withdraw consent at any time.
- Legal obligation: Where required to comply with applicable Malaysian law or a lawful order.
3. How We Use Your Data
- To respond to your enquiry and provide information about programmes.
- To administer your enrolment, provide access to materials and collect payment.
- To review submitted work and provide tutor feedback.
- To issue written records of completion.
- To maintain access to forums and alumni communities for the permitted period.
- To communicate about schedule changes, content updates or programme matters relevant to your enrolment.
- To analyse aggregate usage patterns and improve programme content (using anonymised or pseudonymised data where possible).
- Where consent has been given: to send information about new programmes or cohort openings. You may opt out at any time by emailing [email protected].
4. Data Retention
- Enquiry data: Retained for 12 months from the date of enquiry if no enrolment follows.
- Enrolment and programme data: Retained for 5 years from the end of your programme for record-keeping and to support any future reference requests.
- Payment records: Retained for 7 years as required by Malaysian financial record-keeping obligations.
- Forum posts: Retained for the duration of the forum's operation; you may request removal of your own posts at any time.
- Analytics data: Aggregated and anonymised after 26 months.
5. Data Sharing
We do not sell personal data. We share data only in the following circumstances:
- Payment processors: Payment data is shared with our payment processing provider solely to complete your transaction.
- Hosting and infrastructure providers: Our website and programme platform are hosted on third-party infrastructure. These providers process data on our behalf under data processing agreements.
- Analytics providers: Where consent is given, anonymised usage data is shared with analytics services.
- Legal requirements: Where required by Malaysian law or a lawful authority, we may disclose data as obligated.
6. Data Protection Measures
- Data in transit is protected using TLS encryption.
- Access to participant data is restricted to personnel who require it to perform programme administration duties.
- Submitted programme work (notebooks, audits, reports) is stored in access-controlled environments.
- In the event of a personal data breach that is likely to result in risk to individuals, we will notify affected persons and, where required, the relevant authority without undue delay.
7. Cookies
We use cookies on this website. Essential cookies are required for the site to function. Optional analytics and preference cookies are used only where you have given consent via the cookie banner. For full details see our Cookie Policy.
8. Your Rights Under the PDPA (Malaysia)
Under the Personal Data Protection Act 2010, you have the right to:
- Access: Request a copy of the personal data we hold about you.
- Correction: Request correction of inaccurate or incomplete personal data.
- Withdrawal of consent: Withdraw consent to processing where consent is the legal basis. Withdrawal does not affect processing that occurred prior to withdrawal.
- Objection: Object to processing based on legitimate interest where your particular circumstances warrant it.
- Complaint: Lodge a complaint with the Department of Personal Data Protection Malaysia (PDPD) if you believe your rights under the PDPA have been infringed.
To exercise any of these rights, contact us at [email protected]. We will respond within 21 days.
9. Third-Party Links
Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and recommend you review their privacy policies before providing any personal data.
10. Children's Privacy
Our programmes are intended for adults aged 18 and over. We do not knowingly collect personal data from persons under 18. If you believe a minor has submitted data to us, please contact us at [email protected] and we will delete it promptly.
11. Changes to This Policy
We may update this policy from time to time. Changes will be posted on this page with a revised "Last Updated" date. Where changes are material, we will notify enrolled participants by email at least 14 days before the change takes effect. Continued use of our services after that date constitutes acceptance of the revised policy.
12. Contact
For any questions about this policy or to exercise your data rights:
Sparsemind
55 Jalan Harimau, Taman Century, 80250 Johor Bahru, Johor, Malaysia
Email: [email protected]
Phone: +60 7-419 6820