This Privacy Policy explains how Chance Capital Ventures PLT. trading as Sublet Doctor (“Sublet Doctor”, “we”, “us” or “our”) collects, uses, discloses, stores and otherwise processes personal data in connection with our websites, training programs, events, registrations, enquiries, marketing activities and related services.
We are committed to handling personal data in accordance with the Personal Data Protection Act 2010 [Act 709], as amended from time to time, and other applicable Malaysian laws.
1. WHO WE ARE
Chance Capital Ventures PLT.
Trading as: Sublet Doctor
A-11-02, Menara Uncang Emas UE3, 85, Jalan Loke Yew,
55200 Cheras, Wilayah Persekutuan Kuala Lumpur, Malaysia.
Email: [insert privacy/contact email]
Telephone: [insert telephone number]
Registration No.: [insert PLT registration number]
For the purposes of applicable Malaysian personal-data law, Chance Capital Ventures PLT. acts as the data controller in relation to personal data processed for its own business purposes.
2. PERSONAL DATA WE MAY COLLECT
Depending on how you interact with us, we may collect personal data including:
- name;
- telephone number;
- email address;
- address;
- age or age range where relevant;
- occupation or business information;
- property or rental-related information that you voluntarily provide;
- webinar, event or masterclass registration details;
- enrolment and attendance information;
- payment and transaction information;
- communications through WhatsApp, Telegram, email, telephone or other channels;
- enquiries, support requests and feedback;
- IP address;
- device, browser and operating-system information;
- website usage, page views and referral information;
- advertising, campaign and attribution data;
- cookie identifiers and similar technology;
- information you voluntarily provide in surveys, forms, applications or consultations; and
- any other information reasonably necessary to provide our services.
We generally do not require sensitive personal data unless it is genuinely necessary for a specific purpose.
3. HOW WE COLLECT PERSONAL DATA
We may collect personal data:
- directly from you;
- when you submit a website form;
- when you register for a webinar, masterclass, event or program;
- when you purchase or enrol in a service;
- when you communicate with us through WhatsApp, Telegram, email, telephone or social media;
- when you participate in surveys, events or consultations;
- automatically through cookies, analytics tools and similar technologies;
- from advertising platforms or referral partners where permitted by law; and
- from service providers acting on our behalf.
4. PURPOSES FOR WHICH WE USE PERSONAL DATA
We may process personal data for purposes including:
- processing registrations and enrolments;
- providing training, events, programs, services and support;
- communicating class schedules, reminders, updates and administrative information;
- responding to enquiries and support requests;
- processing payments and maintaining transaction records;
- managing attendance, membership and community access;
- providing learning resources;
- improving our website, services and customer experience;
- conducting analytics and measuring campaign performance;
- preventing fraud, misuse and security incidents;
- maintaining business, accounting and compliance records;
- handling complaints, disputes and legal claims;
- complying with legal, regulatory or governmental requirements;
- sending marketing or promotional communications where permitted by law; and
- any other purpose notified to you at the time of collection.
We will not use personal data for an unrelated purpose without an appropriate lawful basis or further notice where required.
5. MARKETING COMMUNICATIONS
Where permitted by law, we may use your contact details to send information about Sublet Doctor programs, events, educational content, promotions and related services.
Marketing communications may be sent through channels such as:
- email;
- WhatsApp;
- SMS;
- telephone; or
- other communication platforms you have provided to us.
You may opt out of promotional communications at any time by using the unsubscribe mechanism provided or by contacting us.
Administrative or service-related communications may still be sent where necessary for a service you have registered for or purchased.
6. DISCLOSURE OF PERSONAL DATA
We may disclose personal data where reasonably necessary to:
- employees and authorised personnel;
- trainers, coaches and operational staff;
- website, hosting and technology providers;
- CRM and marketing automation providers;
- email, SMS and WhatsApp communication providers;
- webinar and video-conferencing providers;
- payment processors and financial service providers;
- analytics and advertising platforms;
- professional advisers such as accountants, auditors or lawyers;
- regulators, law-enforcement agencies, courts or government bodies where required by law; and
- business partners or contractors who provide services on our behalf.
We require service providers handling personal data on our behalf to use it only for authorised purposes and to maintain appropriate safeguards.
We do not sell personal data to third parties.
7. PAYMENT INFORMATION
Where payments are processed through third-party payment providers, certain payment information may be collected directly by those providers.
We may receive transaction references, payment status and other information necessary to administer your purchase.
Payment providers may process information according to their own privacy policies and legal obligations.
8. COOKIES AND SIMILAR TECHNOLOGIES
Our Website may use cookies and similar technologies for:
- essential website functionality;
- security;
- remembering preferences;
- analytics;
- measuring website performance;
- advertising;
- remarketing; and
- campaign attribution.
Some cookies may be provided by third parties such as analytics or advertising platforms.
Where applicable, you may manage non-essential cookies through available cookie settings or browser controls.
Disabling certain cookies may affect some Website functions.
9. ANALYTICS AND ADVERTISING
We may use services such as Google advertising and analytics tools, Meta advertising tools and other digital platforms to understand Website usage, measure advertising performance and show relevant advertising.
These providers may use cookies, pixels or similar technologies subject to their own policies.
Where required, we will provide appropriate notice or obtain consent for such technologies.
10. CROSS-BORDER TRANSFERS
Some of our service providers, technology platforms or systems may store or process personal data outside Malaysia.
Where personal data is transferred outside Malaysia, we will take reasonable steps to ensure that the transfer is carried out in accordance with the Personal Data Protection Act 2010 and applicable regulatory requirements.
This may include relying on an applicable legal condition, contractual safeguards, consent where appropriate or other permitted mechanisms.
11. DATA SECURITY
We take reasonable administrative, organisational and technical measures to protect personal data against:
- unauthorised access;
- loss;
- misuse;
- alteration;
- disclosure; and
- destruction.
However, no internet transmission or electronic storage system can be guaranteed to be completely secure.
12. DATA BREACHES
Where we become aware of a personal-data breach, we will assess and respond to it in accordance with applicable Malaysian law.
Where required, we will notify the Personal Data Protection Commissioner and affected individuals in accordance with applicable statutory requirements.
13. DATA RETENTION
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including:
- provision of services;
- contractual administration;
- accounting and taxation;
- legal or regulatory compliance;
- fraud prevention;
- dispute resolution;
- security; and
- legitimate business record-keeping.
When personal data is no longer reasonably required, we will take appropriate steps to delete, destroy or anonymise it, subject to applicable legal obligations.
14. YOUR RIGHTS
Subject to applicable Malaysian law, you may have rights in relation to your personal data, including the right to:
- request access to personal data held about you;
- request correction of inaccurate or incomplete data;
- withdraw consent where processing relies on consent, subject to legal or contractual limitations;
- request that certain marketing communications stop;
- make enquiries or complaints regarding our handling of personal data; and
- exercise other rights available under applicable Malaysian law.
- To exercise a right or make a privacy request, please contact us using the details below.
We may need to verify your identity before processing certain requests.
15. CHILDREN
Our services are generally intended for adults.
We do not knowingly seek to collect personal data from children without appropriate parental or guardian involvement where required by law.
If you believe that a child has provided personal data to us improperly, please contact us.
16. EXTERNAL WEBSITES AND THIRD-PARTY SERVICES
Our Website may contain links to websites or services operated by third parties.
We are not responsible for the privacy practices of independent third parties.
You should review the privacy notice of any third-party website or service you use.
17. FEEDBACK, TESTIMONIALS AND USER CONTENT
If you provide feedback, reviews, testimonials, photographs, videos or other content, we will not publicly identify or publish your personal information for promotional purposes without appropriate permission where required.
We may use de-identified or aggregated feedback for internal improvement and analysis.
18. DATA PROTECTION OFFICER
Where Sublet Doctor is required under applicable law to appoint a Data Protection Officer, the relevant contact information will be made available through our Website or other appropriate channel.
19. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in law, technology, services or our data-processing practices.
The latest version will be published on this page together with the most recent revision date.
Where a change materially affects how we use personal data, we will provide additional notice where reasonably appropriate or legally required.
20. CONTACT US
For questions, access/correction requests, complaints or other privacy matters, please contact:
Chance Capital Ventures PLT. / Sublet Doctor
A-11-02, Menara Uncang Emas UE3, 85, Jalan Loke Yew
55200 Cheras
Wilayah Persekutuan Kuala Lumpur
Malaysia
Privacy Email: [insert email]
Telephone: [insert telephone number]