Privacy Policy

1. Introduction

Twiline ("we", "our", "us") is committed to protecting the personal data of individuals who interact with our services. This Privacy Policy explains how we collect, use, store, and protect personal information in connection with our retirement information and document organisation services, operated from 17 Jalan Gaya, 88000 Kota Kinabalu, Sabah, Malaysia.

This policy applies to personal data collected through our website at twilinedas.pro, through enquiry forms, direct communications, and in connection with service bookings. By using our website or enquiring about our services, you acknowledge the practices described here.

2. Data We Collect

We collect personal data only for specific, legitimate purposes related to our services. The types of personal data we may collect include:

• Name and contact details (email address, telephone number)
• Correspondence you send to us (including enquiry messages)
• Booking and session scheduling information
• Feedback provided after sessions
• Technical data collected through cookies and analytics tools (see Section 5)

We do not collect or retain copies of any personal documents handled during sessions. Session notes are produced by and remain with the participant.

3. How We Use Your Data

We use your personal data for the following purposes:

• Responding to your enquiries about our services
• Scheduling and confirming service bookings
• Delivering sessions and sending follow-up materials by post where applicable
• Improving the quality of our services based on participant feedback
• Complying with applicable legal obligations in Malaysia

We do not use your personal data for automated decision-making or profiling. We do not sell, rent, or trade your personal data to third parties.

4. Legal Basis for Processing

We process your personal data on the following legal bases under the Personal Data Protection Act 2010 (PDPA) of Malaysia:

• Consent: Where you have provided consent by submitting an enquiry form or requesting a session booking.
• Contractual necessity: Where processing is required to fulfil a service booking you have made.
• Legitimate interests: For improving our services and responding to general enquiries, where your rights and interests are not overridden.

5. Cookies and Analytics

Our website uses cookies to support basic functionality and to understand how visitors use the site. Analytics cookies help us identify which pages are visited most frequently. You may manage your cookie preferences through the cookie consent banner on our homepage or by visiting our Cookie Policy page.

We may use Google Analytics or similar tools for this purpose. These services may set their own cookies in accordance with their respective privacy policies.

6. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected:

• Enquiry and booking data: retained for up to 24 months from the date of last contact
• Session feedback: retained for up to 12 months from submission
• Financial transaction records (if applicable): retained for 7 years in accordance with Malaysian tax and accounting requirements

After the applicable retention period, personal data is securely deleted or anonymised.

7. Data Protection Measures

We take reasonable and appropriate steps to protect personal data from unauthorised access, disclosure, or loss. These measures include:

• Secure storage of contact records with access limited to authorised team members
• Use of encrypted email communication where practicable
• Physical documents and printed session materials are not retained by Twiline after handover to participants
• Regular review of data handling practices

8. Third-Party Services

Our website may link to third-party services or websites. We are not responsible for the privacy practices of those parties. We may share data with the following categories of third-party providers:

• Email service providers for communications
• Analytics platforms (e.g. Google Analytics)
• Postal and courier services for material delivery

Where third-party processors handle personal data on our behalf, we ensure appropriate data processing agreements are in place.

9. Your Rights Under Malaysian Law

Under the Personal Data Protection Act 2010 (PDPA), you have the following rights regarding your personal data:

• Right to access the personal data we hold about you
• Right to request correction of inaccurate or incomplete data
• Right to withdraw consent where consent is the basis of processing
• Right to request the cessation of processing that is causing damage or distress

To exercise any of these rights, please contact us at [email protected] or by post to our registered address. We will respond within 21 days of receipt.

10. Children's Privacy

Our services are directed at adults, typically those aged 50 and above, and their adult family members. We do not knowingly collect personal data from persons under the age of 18. If you believe we have inadvertently collected data from a minor, please contact us so we can take corrective action.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated date at the top of this page will be revised accordingly. We encourage you to review this page periodically. Continued use of our website after any changes constitutes acceptance of the updated policy.

12. Contact Information

For questions about this Privacy Policy or your personal data, please contact:

• Email: [email protected]
• Address: Twiline, 17 Jalan Gaya, 88000 Kota Kinabalu, Sabah, Malaysia
• Telephone: +60 88 254 3617