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Privacy Policy

How we collect, use, disclose and protect personal data

Effective date:

[INSERT PUBLICATION DATE]

Last updated:

23 September 2026

CDE Flash Card respects your privacy. This Privacy Policy explains how [REGISTERED COMPANY NAME], operating as CDE Flash Card ("CDE Flash Card", "we", "us" or "our"), collects, uses, stores, discloses and protects personal data when you use our website, application, account, subscriptions, customer support and related services.

CDE Flash Card accounts are intended to be created and managed by parents, legal guardians or other authorised adults. Children should use the learning content only under adult supervision and should not submit personal data directly to us.

1. Who Operates CDE Flash Card

Legal entity:

[REGISTERED COMPANY NAME]

Registration no. :

[COMPANY REGISTRATION NUMBER]

Business address:

[REGISTERED BUSINESS ADDRESS]

Privacy email:

[PRIVACY EMAIL ADDRESS]

Support email:

[SUPPORT EMAIL ADDRESS]

2. Personal Data We May Collect

The personal data we collect depends on how you use CDE Flash Card.

2.1 Information You Provide

• Name, email address, telephone number and account credentials

• Billing address, subscription selection and transaction details

• Messages, enquiries, feedback, survey responses and support records

• Screenshots or files you voluntarily send to us

• Marketing and communication preferences

• Any other information you choose to provide through our forms or services

2.2 Payment Information

Payments may be processed by [PAYMENT PROVIDER NAME]. The payment provider may collect payment-card, bank, electronic-wallet, billing, fraud-prevention and transaction information under its own privacy policy. We generally receive limited details such as payment status, transaction reference, subscription type and payment date. We do not directly store complete payment-card details unless clearly stated at the point of collection.

2.3 Information Collected Automatically

• Internet Protocol address and general location derived from it

• Device type, device identifiers, browser, operating system and language settings

• Login times, pages, features and learning topics accessed

• Session duration, referral source and interaction data

• Cookie, local-storage or similar technology identifiers

• Performance information, crash reports and error logs

2.4 Information About Children

We do not require a child to provide a full name, email address, telephone number, photograph, school information or precise location to access learning content. Parents and guardians should avoid submitting unnecessary child-identifying information. If we learn that personal data was submitted by a child without appropriate adult involvement, we will take reasonable steps to review and remove it where required.

3. How We Collect Personal Data

We may collect personal data directly from you when you create an account, subscribe, make a payment, contact us, complete a form or use the service. We may also receive data automatically through our website or app and from service providers such as payment, authentication, hosting, analytics and customer-support providers.

4. How We Use Personal Data

• Create, authenticate and manage accounts

• Provide access to learning content and subscription features

• Process payments and maintain transaction and subscription records

• Respond to enquiries, provide support and resolve technical problems

• Remember settings and improve content, features and user experience

• Monitor performance, diagnose errors and understand service usage

• Protect accounts and detect fraud, misuse and security incidents

• Send essential account, payment, security and service communications

• Send promotional communications where permitted and according to your preferences

• Manage partnerships, business enquiries and legal claims

• Comply with legal, regulatory, tax, accounting and reporting obligations

5. Legal Basis and Consent

We process personal data with your consent where consent is required, to provide services you request, to meet legal obligations and for legitimate operational purposes permitted by applicable law. You may withdraw consent for future processing where the processing depends on consent, but withdrawal does not affect processing already carried out lawfully and may limit our ability to provide certain services.

6. Cookies and Similar Technologies

We may use cookies, software development kits, pixels, local storage and similar technologies to keep users signed in, remember preferences, maintain security, measure performance, diagnose problems and understand how the service is used.

Essential technologies support core functions. Analytics, functionality or marketing technologies will be used in accordance with applicable requirements and any controls made available to you. You may adjust browser or device settings, although disabling certain technologies may affect service functionality.

Cookie and analytics providers:

[INSERT PROVIDER NAMES OR STATE NONE]

7. When We Disclose Personal Data

We do not sell or rent personal data. We may disclose personal data when reasonably necessary to the following recipients:

• Hosting, cloud-storage, database and authentication providers

• Payment processors and fraud-prevention providers

• Email, messaging and customer-support providers

• Analytics, performance-monitoring and security providers

• Professional advisers such as lawyers, auditors and accountants

• Authorities, regulators or law-enforcement bodies where disclosure is legally required

• A buyer, investor or successor in connection with a proposed or completed business transaction, subject to appropriate safeguards

Current key service providers:

[HOSTING PROVIDER], [DATABASE OR AUTHENTICATION PROVIDER], [PAYMENT PROVIDER], [ANALYTICS PROVIDER], [EMAIL PROVIDER] and [CUSTOMER SUPPORT PROVIDER].

8. International Data Transfers

Some service providers may process or store personal data outside Malaysia. Where personal data is transferred internationally, we will take reasonable steps and apply safeguards required by Malaysian law. These may include assessing the destination and provider, contractual protection, security controls and other legally recognised transfer conditions.

Likely processing locations:

[INSERT COUNTRIES AFTER CONFIRMING WITH PROVIDERS].

9. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including providing the service, maintaining accounts and subscriptions, processing transactions, resolving disputes, preventing fraud and meeting legal, tax, accounting and regulatory obligations.

Retention periods vary by data type. When information is no longer required, we will take reasonable steps to delete, destroy or anonymise it, subject to lawful record-keeping needs.

10. Data Security

We use reasonable administrative, technical and organisational measures to protect personal data against loss, misuse, unauthorised access, alteration, disclosure or destruction. Measures may include access controls, authentication, secure hosting, backups, monitoring and confidentiality requirements.

No online system is completely secure. If a personal data breach occurs, we will investigate and notify the relevant authority and affected individuals where required by applicable law.

11. Your Rights and Choices

Subject to applicable law and permitted exceptions, you may ask us to:

• Provide access to personal data we hold about you

• Correct inaccurate or incomplete personal data

• Withdraw consent where processing depends on consent

• Stop using your personal data for direct marketing

• Close your account or delete personal data that we are not legally required to retain

• Transfer personal data to another data controller where a legal portability right applies

• Explain our handling of your personal data or review a privacy complaint

Submit requests to [PRIVACY EMAIL ADDRESS]. We may verify your identity before acting and may retain certain records where required for legal, security, accounting, fraud-prevention or dispute-resolution purposes.

12. Marketing Communications

We may send educational updates, product news or promotional offers where you have consented or where otherwise permitted by law. You can opt out through an unsubscribe link, account preference or by contacting [SUPPORT OR PRIVACY EMAIL]. You may still receive essential messages concerning your account, payment, security or subscription.

13. Account Closure

You may request account closure through any account-deletion feature provided in the service or by contacting [SUPPORT EMAIL ADDRESS]. Closing an account may end access to subscription content and saved preferences. We may retain limited records where legally required or reasonably necessary to protect the service, resolve disputes or enforce agreements.

14. Third Party Links and Services

The service may link to external websites, applications or services. We do not control their privacy practices. Please review the privacy notice of any third party before providing personal data.

15. Changes to This Privacy Policy

We may update this Privacy Policy when our services, data practices, providers or legal obligations change. The revised policy will be posted with a new Last Updated date. Where a change materially affects how we handle personal data, we may provide additional notice through the service or registered email address where appropriate.

16. Contact and Complaints

Questions, requests or complaints may be sent to:

CDE Flash Card, operated by [REGISTERED COMPANY NAME], [REGISTERED BUSINESS ADDRESS]. Privacy email: [PRIVACY EMAIL ADDRESS]. Support email: [SUPPORT EMAIL ADDRESS].

If you are dissatisfied with our response, you may contact the Personal Data Protection Commissioner of Malaysia, subject to the procedures and rights available under applicable law.

17. Language

This Privacy Policy may be provided in Bahasa Malaysia, English and other languages. If translated versions differ, the version designated by us as controlling will apply only to the extent permitted by law. Nothing in this section limits any mandatory language or notice requirement under Malaysian law.