Privacy Policy

1. Introduction

Denari ("we", "us", "our") is committed to handling personal information responsibly and in accordance with the Personal Data Protection Act 2010 (PDPA) of Malaysia. This Privacy Policy describes what personal data we collect, how we use it, and the rights available to individuals in respect of their data.

This policy applies to personal data collected through our website at https://denari.club, through our contact form, and through participation in our financial literacy programmes. By using our website or engaging with our services, you acknowledge the practices described in this policy.

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

2. Data We Collect

We collect the following categories of personal data:

• Contact details: name, email address, phone number (when provided)
• Enquiry information: the content of messages submitted via our contact form
• Programme participation data: attendance records and feedback submitted during or after sessions
• Technical data: IP addresses, browser type, pages visited (collected via cookies and analytics tools)

We do not collect financial account numbers, passport or identification numbers, or any sensitive personal data as defined under the PDPA.

Retention periods: Contact and enquiry data is retained for 24 months from the date of last interaction. Programme attendance records are retained for 36 months. Technical/analytics data is retained for 13 months.

3. Legal Basis and How We Use Your Data

We process personal data on the following legal bases under the PDPA:

• Consent: when you submit a contact form or agree to receive communications
• Contractual necessity: to administer programme enrolments and deliver services
• Legitimate interests: to improve our programmes, respond to enquiries, and maintain security of our systems

We use personal data to: respond to your enquiries; confirm and manage programme bookings; send relevant information about sessions you have registered for; improve our website and content; and comply with any applicable legal obligations.

We do not use your personal data for automated decision-making or profiling.

4. Data Sharing

We do not sell, rent, or trade personal data. We may share data with:

• Service providers: hosting providers and email platforms operating under data processing agreements
• Analytics tools: anonymised or aggregated data may be processed by analytics services (e.g. Google Analytics)
• Legal obligations: where required by law or a competent authority in Malaysia

Any third-party service provider engaged by Denari is contractually required to process data only as instructed and to maintain appropriate security measures.

5. Data Protection Measures

We take reasonable technical and organisational steps to protect personal data against unauthorised access, disclosure, or loss. These include:

• HTTPS encryption for all data transmitted through our website
• Access controls limiting staff access to personal data on a need-to-know basis
• Regular review of security practices and third-party service arrangements

In the event of a data breach that is likely to result in harm to affected individuals, we will notify the Personal Data Protection Commissioner and affected individuals as required by applicable law.

6. Cookies

Our website uses cookies to function correctly and to understand how visitors use the site. Cookie categories include essential, analytics, preference, and marketing cookies. You can manage your cookie preferences at any time via our Cookie Policy page.

7. Your Rights

Under the PDPA and applicable data protection principles, you have the right to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete personal data
• Request erasure of your personal data (subject to legal retention requirements)
• Withdraw consent where processing is based on consent
• Object to processing based on legitimate interests
• Lodge a complaint with the Personal Data Protection Commissioner of Malaysia

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. We may ask you to verify your identity before acting on a request.

8. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and recommend reviewing their privacy policies before providing any personal data.

9. Children's Privacy

Our programmes and website are intended for individuals aged 18 and over. We do not knowingly collect personal data from persons under 18. If we become aware that we have inadvertently collected such data, we will delete it promptly.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the revised policy on this page with an updated "Last Updated" date. Continued use of our website or services after any changes constitutes acceptance of the revised policy.

11. Contact

Data Controller: Denari
No. 23, Persiaran Multimedia, 63000 Cyberjaya, Selangor, Malaysia
Email: [email protected]
Phone: +60 17-642 8095