Privacy Policy

1. Introduction

Flowry ("we", "us", "our") is committed to protecting the personal data of everyone who visits our website or enrols in our household cash flow education programs. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have over it.

This policy applies to personal data processed through our website at flowry.cyou and through our program enrolment and communications processes. If you have questions, contact us at [email protected].

2. Data We Collect

We collect personal data through the following means:

2.1 Information You Provide

• Full name (when submitting the contact form or registering for a program)
• Email address (required for communication and program access)
• Phone number (optional — provided voluntarily via the contact form)
• Message content (when you contact us through our website form)

2.2 Automatically Collected Data

• Browser type, device type, and operating system
• Pages visited and time spent on each page
• Referring website or search term (where applicable)
• IP address (anonymised for analytics)

2.3 Legal Basis for Processing

We process your personal data under the following bases as provided by Malaysia's Personal Data Protection Act 2010 (PDPA): your consent (when you submit a form or accept cookies), the performance of a contract (when you enrol in a program), and our legitimate interest in improving our educational services.

2.4 Data Retention

Contact enquiry data is retained for up to 24 months. Program enrolment records are retained for up to 5 years from the end of the program, consistent with record-keeping requirements under Malaysian law. You may request deletion at any time (see Section 6).

3. How We Use Your Data

• To respond to your enquiries and provide information about our programs
• To process program enrolments and deliver course or workshop access
• To send administrative communications related to your program (schedules, materials)
• To improve our website content and user experience using anonymised analytics data
• To comply with applicable Malaysian law and regulatory requirements

We do not sell your personal data to third parties. We do not use your data for profiling or automated decision-making. Marketing communications (if any) will only be sent with your explicit consent, and you may opt out at any time.

3.1 Third-Party Service Providers

We may share limited data with trusted service providers who help us operate our website and programs (such as email delivery services and web hosting providers). These providers are bound by confidentiality obligations and may not use your data for their own purposes.

4. Data Security

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

• SSL/TLS encryption for all data transmitted through our website
• Restricted access to personal data — only authorised team members handle it
• Regular review of our data handling practices
• Secure, access-controlled storage for program records

In the event of a personal data breach that affects your rights, we will notify affected individuals and the relevant authority as required under the PDPA within the applicable timeframe.

5. Cookies

Our website uses cookies to remember your preferences and understand how visitors use the site. We use essential cookies (required for the site to function), analytics cookies (to understand page usage), and preference cookies (to remember your settings).

You can manage your cookie preferences at any time via our Cookie Policy page. Rejecting optional cookies will not affect your access to our website.

6. Your Rights

Under the Malaysian Personal Data Protection Act 2010, you have the following rights with respect to your personal data:

• Right to access: Request a copy of the personal data we hold about you
• Right to correction: Request correction of inaccurate or incomplete data
• Right to withdraw consent: Withdraw consent for data processing at any time (where processing is based on consent)
• Right to limit processing: Request that we restrict how we use your data in certain circumstances
• Right to erasure: Request deletion of your personal data, subject to our legal retention obligations

To exercise any of these rights, contact us at [email protected]. We will respond within 21 days of receiving a valid request.

If you are unsatisfied with how we handle your request, you may contact the Department of Personal Data Protection Malaysia (JPDP), the relevant supervisory authority under the PDPA.

7. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices or content of those websites. We encourage you to read the privacy policies of any external sites you visit.

8. Children's Privacy

Flowry's programs are designed for adults aged 18 and above. We do not knowingly collect personal data from individuals under 18 years of age. If we become aware that we have collected data from a minor, we will take steps to delete it promptly.

9. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. For material changes, we will provide notice through our website or by email to enrolled learners. Continued use of our website after changes take effect constitutes acceptance of the updated policy.