Privacy Policy

1. Introduction

Everlyn Mosvar ("we", "us", "our") is committed to protecting the personal data of individuals who engage with our services. This policy explains how we collect, use, store, and protect personal information in connection with our financial education programmes, website, and related communications.

This policy is issued in accordance with the Personal Data Protection Act 2010 (Malaysia) ("PDPA") and applies to all participants, enquirers, and visitors to our website at everlynm.pro.

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

2. Data We Collect

We may collect the following personal data:

• Full name and contact details (email address, telephone number)
• Correspondence submitted through our enquiry form
• Programme enrolment and participation records
• Website usage data via analytics cookies (where consent is given)
• Payment information (processed through third-party payment providers; we do not store card data)

We collect only the data necessary for the purposes described in this policy. We do not collect sensitive personal data.

3. How We Use Your Data

Personal data collected is used for the following purposes:

• Programme administration: Processing enrolments, delivering study materials, managing facilitator sessions.
• Communication: Responding to enquiries, sending programme-related updates and reminders.
• Service improvement: Analysing aggregate programme feedback and website usage to improve our offerings.
• Legal compliance: Meeting obligations under Malaysian law, including record-keeping requirements.

We do not use personal data for direct marketing without explicit consent. We do not sell, rent, or share personal data with third parties for commercial purposes.

4. Legal Basis for Processing

We process personal data on the following legal bases under the PDPA 2010:

• Consent: For communications beyond programme delivery, and for analytics cookies.
• Contract performance: For programme enrolment and delivery.
• Legitimate interests: For improving services and managing enquiries.
• Legal obligation: For compliance with applicable Malaysian law.

5. Data Retention

We retain personal data for as long as necessary for the purposes described above, or as required by law. Enrolment records are retained for a maximum of five years following programme completion. Enquiry correspondence is retained for twenty-four months unless enrolment follows, in which case the enrolment retention period applies. Analytics data is retained in aggregate form only.

6. Data Protection Measures

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

• Encrypted data transmission via HTTPS
• Access controls limiting data access to authorised personnel
• Secure third-party payment processing (we do not store payment card data)
• Regular review of data handling procedures

7. Cookies

Our website uses cookies to understand how it is used. Essential cookies are necessary for the site to function. Optional analytics and preference cookies are only set with your consent. Full details are available in our Cookie Policy.

8. Third-Party Services

We may use the following third-party services in connection with our website and programmes:

• Google Analytics (website usage analysis, with anonymisation enabled)
• Email delivery providers for programme communications
• Third-party payment processors for enrolment fees

These parties process data only on our instructions and are required to maintain appropriate data protection standards. We are not responsible for the privacy practices of third-party websites linked from our site.

9. Your Rights

Under the PDPA 2010, you have the right to:

• Access personal data we hold about you
• Correct inaccurate or incomplete data
• Withdraw consent for processing where consent is the legal basis
• Request erasure of data we no longer have a lawful basis to retain
• Lodge a complaint with the Department of Personal Data Protection Malaysia

To exercise any of these rights, contact us at [email protected]. We will respond within fourteen working days.

10. Children's Privacy

Our programmes are designed for adults aged eighteen and above. We do not knowingly collect personal data from individuals under eighteen. If we become aware that we have inadvertently received data from a minor, we will delete it promptly.

11. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or applicable law. The updated policy will be posted on this page with a revised date. Continued use of our services after the update date constitutes acceptance of the revised policy.

12. Contact