Privacy Policy
Last Updated: 15 June 2025 • Effective Date: 15 June 2025
Frugova ("we", "us", "our") is committed to handling personal information responsibly and transparently. This Privacy Policy explains how we collect, use, store, and protect data in connection with our website and spending education programs, and describes the rights available to individuals whose data we process.
This policy applies to all visitors to our website at frugova.cyou and to participants in Frugova's courses, workshops, and programs. By using our website or submitting an enquiry, you acknowledge that you have read and understood this policy.
1. Data Controller
The data controller for personal information collected through Frugova's website and programs is:
Frugova
Jalan Damansara, 60000 Kuala Lumpur, Malaysia
Email: [email protected]
2. What Personal Data We Collect
We collect the following categories of personal data:
- Contact details: name, email address, and phone number (where provided), collected via our enquiry form
- Enquiry content: any information you include in your message when contacting us
- Program participation data: attendance, session participation, and feedback provided during or after programs
- Technical data: IP address, browser type, pages visited, and device information, collected automatically via cookies and analytics tools
We collect only what is reasonably necessary for the purposes described in this policy.
3. How We Collect Data
- Directly from you, when you submit our contact form or register for a program
- Automatically, through cookies and web analytics tools when you visit our website
- During program delivery, through session interactions, exercises, and feedback
4. Legal Basis for Processing
We process personal data on the following legal bases under Malaysian data protection law (Personal Data Protection Act 2010, PDPA):
- Consent: where you have given clear consent, such as submitting our enquiry form or accepting cookies
- Contractual necessity: where processing is needed to fulfil a program enrollment or respond to an enquiry
- Legitimate interests: for analytics and website improvement, provided your interests and rights are not overridden
- Legal compliance: where we are required to process or retain data by applicable law
5. How We Use Your Data
- To respond to enquiries and provide information about our programs
- To deliver courses, workshops, and programs you have enrolled in
- To send administrative communications related to your enrollment
- To improve our website content and program delivery based on usage data and feedback
- To comply with applicable legal requirements
We do not send marketing emails without your consent, and you may withdraw consent for marketing communications at any time by contacting us at [email protected].
6. Data Sharing
We do not sell personal data. We may share data in the following limited circumstances:
- Service providers: third-party tools used to operate our website or deliver programs (such as email delivery services and analytics platforms), under data processing agreements
- Legal requirements: where we are required by law to disclose information to a relevant authority
We take reasonable steps to ensure any third parties we work with handle data responsibly and in line with applicable law.
7. Data Retention
We retain personal data for as long as is necessary for the purposes for which it was collected:
- Enquiry data: up to 12 months from the date of enquiry, unless a program enrollment follows
- Program participation data: up to 3 years from the date of program completion
- Technical/analytics data: typically 26 months, depending on the tool
After retention periods expire, data is securely deleted or anonymised.
8. Data Protection Measures
We take reasonable technical and organisational measures to protect personal data from unauthorised access, loss, or disclosure. These include:
- Encrypted data transmission via HTTPS
- Access controls limiting who within Frugova can access personal data
- Regular review of our data handling practices
- Prompt notification to affected individuals if a data breach occurs and is likely to affect their rights and freedoms
9. Cookies
Our website uses cookies to support basic functionality, understand how the site is used, and improve the experience for visitors. You can manage your cookie preferences via the banner displayed when you first visit our site, or through your browser settings. For full details, please read our Cookie Policy.
10. Your Rights
Under the Malaysian 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 or incomplete data be corrected
- Withdrawal of consent: where processing is based on consent, you may withdraw it at any time
- Objection: you may object to processing for certain purposes, including marketing
- Erasure: in certain circumstances, you may request deletion of your personal data
To exercise any of these rights, contact us at [email protected]. We will respond within a reasonable timeframe and in accordance with applicable law.
11. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to read their privacy policies before providing any personal information.
12. Children's Privacy
Frugova's programs and website are intended for individuals aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that data has been collected from a minor, we will take steps to delete it promptly.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will update the "Last Updated" date at the top of this page. Continued use of our website or programs after changes take effect constitutes acceptance of the updated policy.
14. Contact for Privacy Matters
For any questions, requests, or concerns about this policy or how we handle your data, please contact:
Frugova Privacy
Email: [email protected]
Address: Jalan Damansara, 60000 Kuala Lumpur, Malaysia