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Privacy Policy

Last Updated: 28 May 2025  ·  Effective: 28 May 2025

1. Introduction

Driftwood Helm ("we", "us", "our") is committed to handling your personal data responsibly. This Privacy Policy explains what information we collect, how we use it, and the choices available to you. It applies to all personal data collected through our website at driftwoody.club and through enquiries or engagements with our advisory services.

Our services are advisory in nature — we work with online sellers to improve their e-commerce operations. In providing those services, we collect a limited amount of personal information, primarily to communicate with you and to deliver the engagement you have requested.

Questions about this policy may be directed to: [email protected]

2. Data We Collect

2.1 Information You Provide

  • Name and surname
  • Email address
  • Phone number (if provided)
  • Business name and description (if shared during an enquiry)
  • The content of messages sent via our contact form

2.2 Information Collected Automatically

  • IP address and approximate geographic location
  • Browser type and device information
  • Pages visited, time spent, and referring URLs
  • Cookie data (see Section 5 and our Cookie Policy)

2.3 Legal Basis for Processing (PDPA Malaysia)

We process your personal data under the Personal Data Protection Act 2010 (Malaysia). The legal bases we rely on include:

  • Consent: Where you submit a contact form or agree to cookies
  • Contract: Where processing is necessary to deliver an agreed engagement
  • Legitimate interest: For improving our services and communications

3. How We Use Your Data

  • To respond to enquiries submitted through our contact form
  • To deliver and manage advisory engagements
  • To send relevant updates about an active engagement
  • To improve our website and understand how visitors use it (analytics)
  • To meet legal or regulatory obligations where applicable

We do not use your personal data for automated decision-making or profiling that produces legal effects.

4. Data Sharing and Third Parties

We do not sell your personal data. We may share it in the following limited circumstances:

  • Service providers: Hosting and website infrastructure providers who process data on our behalf under appropriate agreements
  • Analytics: We may use analytics tools (such as Google Analytics) to understand site usage. These tools may collect browsing data in accordance with their own privacy policies
  • Legal requirements: Where we are required by law to disclose information to authorities

5. Cookies

Our website uses cookies to support basic functionality and to understand how the site is used. You can manage your cookie preferences via the banner shown on your first visit or through our Cookie Policy page, which includes functional toggle controls.

Essential cookies are required for the site to function. Analytics and marketing cookies are optional and only activated with your consent.

6. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy:

  • Enquiry data (not resulting in an engagement): up to 12 months
  • Engagement-related data: up to 3 years from engagement completion
  • Analytics data: as specified by the third-party analytics provider
  • Cookie consent records: 12 months

After the applicable retention period, data is deleted or anonymised.

7. Data Protection Measures

We take reasonable technical and organisational measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction. These include:

  • HTTPS encryption for data transmitted through our website
  • Restricted internal access to personal data
  • Regular review of data handling practices

In the event of a data breach that is likely to affect your rights, we will notify you and the relevant authorities as required under applicable law.

8. Your Rights

Under the Personal Data Protection Act 2010 (Malaysia) and applicable data protection principles, you have the right to:

  • Access the personal data we hold about you
  • Correct inaccurate or incomplete data
  • Withdraw consent at any time where processing is based on consent
  • Request deletion of your personal data where there is no lawful basis for continued processing
  • Object to processing based on our legitimate interests
  • Lodge a complaint with the Department of Personal Data Protection (PDPD) Malaysia if you believe your rights have been infringed

To exercise any of these rights, write to us at [email protected]. We will respond within 21 days.

9. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites. We recommend reviewing the privacy policy of any external site you visit.

10. Children's Privacy

Our services are intended for businesses and individuals aged 18 and above. We do not knowingly collect personal data from anyone under the age of 18. If you believe we have inadvertently collected such data, please contact us immediately and we will delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. Where changes are material, we will take reasonable steps to notify affected individuals.

12. Contact

For privacy-related enquiries or to exercise your rights:

Driftwood Helm

Level 6, Penang Times Square, 77 Jalan Dato Keramat, 10150 George Town, Penang, Malaysia

Email: [email protected]

Phone: +60 4-227 6481