Privacy Policy

1. Who we are

This Privacy Policy explains how Prime Orator Academy & Consultancy ("Prime Orator", "we", "us") collects, uses, and protects personal data when you visit primeorator.my or engage with our training and consultancy services. Prime Orator (primeorator.my) is a business brand owned by iSpring Solutions (AS0474610-W), which operates this site. Invoices, quotations and payments are issued by and made to iSpring Solutions. This policy is written to comply with Malaysia's Personal Data Protection Act 2010 (PDPA).

2. What personal data we collect

We collect personal data only when you voluntarily provide it to us, through:

• The Contact Us / Consultancy Brief form: your name, company name, email address, phone number, group size, area of interest, and any message you write.
• The HRD Corp Claimable Registration form: your first and last name, company name, email address, and phone number.
• The Botanica Balance registration form: your name, company name, email address, phone number, group size, and any message you write.

We do not knowingly collect sensitive personal data (such as health information, race, or religion) through these forms, and we ask that you do not include such information in free-text fields unless it is directly relevant to a training request (for example, an accessibility requirement).

When you browse the site, our first-party analytics records page views and selected actions such as course-interest clicks, contact-form opens and submissions, brochure opens and requests, and registration starts and successful submissions. It records a normalized page path and, where relevant, an allow-listed course slug. A random browser identifier is used only to estimate repeat browsers; we do not try to identify people or fingerprint devices. Analytics excludes names, email addresses, phone numbers, form contents, full IP addresses, user agents, query strings, and referrer URLs.

3. How we use your personal data

We use the personal data you provide to:

• Respond to your enquiry or consultation request.
• Process your registration for an HRD Corp claimable training programme.
• Contact you regarding a booking, including by phone, email, or WhatsApp.
• Improve our training programmes and website based on aggregated usage patterns.
• Meet our legal and regulatory obligations, including those relating to HRD Corp claims.

4. Who we share your data with

We do not sell your personal data. We share it only with the following third parties, and only as necessary to operate our services:

• Our email provider (Apple iCloud Mail), which delivers the messages our website forms and invoices send to us and to you. Form submissions are received by our own server and emailed to our inbox; they are not passed to any other form-processing service.
• Our first-party analytics system, which stores limited event data on our server and is not shared with an analytics vendor.
• HRD Corp, where your registration relates to a claimable training programme, as required to process levy claims on your employer's behalf.
• Video content on this site is embedded from YouTube in privacy-enhanced mode (youtube-nocookie.com), which limits cookie use unless you choose to play a video.

We do not transfer your personal data outside Malaysia except where a third-party service provider listed above processes data on servers located overseas as part of its standard global infrastructure.

5. Cookies

This site uses a first-party cookie named po_visitor_id for 180 days. It contains a randomly generated identifier, not personal information, and is used to estimate repeat browsers in aggregate reports. Analytics events may include the server timestamp, an allow-listed event name, normalized route, optional course slug, and a SHA-256 hash of that identifier. We exclude names, emails, phone numbers, form contents, full IP addresses, and user agents from analytics. Analytics events are retained on our server for 90 days. You can delete or block cookies through your browser settings; disabling this cookie does not prevent use of the site, but repeat-browser estimates will be less complete.

6. Photographs from training sessions

From time to time, we photograph participants during training sessions for use in our marketing materials and the Gallery page on this site, and on our social media channels. If you attend a Prime Orator training session and do not wish to be photographed, please inform your facilitator or contact us at the details below and we will accommodate your request.

7. Data retention

We retain personal data collected through our forms only for as long as necessary to respond to your enquiry, deliver the training programme you registered for, or meet our legal and financial record-keeping obligations, after which it is securely deleted or anonymised. First-party analytics events are automatically removed after 90 days.

8. Data security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

9. Your rights under the PDPA

Under the Personal Data Protection Act 2010, you have the right to:

• Request access to the personal data we hold about you.
• Request correction of inaccurate personal data.
• Withdraw your consent to our processing of your personal data, subject to any legal or contractual restrictions.
• Limit the processing of your personal data for marketing purposes.

To exercise any of these rights, contact us using the details in Section 11.

10. Children's privacy

Our services are directed at corporate clients and working adults. We do not knowingly collect personal data from children.

11. Contact us

If you have questions about this Privacy Policy or wish to exercise your rights under the PDPA, contact us at:

Prime Orator Academy & Consultancy (a business brand owned by iSpring Solutions (AS0474610-W))
Email: registrar@primeorator.my
Phone: +603 6087 5252
WhatsApp:

12. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. The "Last updated" date at the top of this page indicates when it was last revised.