Effective Date: 18 May 2025
 

Talents Tech Executive Sdn. Bhd. (1203068-V) , together with its branch offices, related entities, affiliates and authorised partners across the Asia-Pacific region (collectively, "TalentsTech", "we", "us" or "our"), is committed to protecting the privacy of individuals whose personal information we handle. This Privacy Policy explains how we collect, use, store, disclose, transfer, retain and delete your Personal Information when you access our website, use our services, or otherwise interact with us.

This Policy is issued in accordance with our obligations under applicable data protection laws, including:

(a) the Personal Data Protection Act 2010 of Malaysia, as amended ("Malaysian PDPA");

(b) the Privacy Act 1988 (Cth) of Australia and the Australian Privacy Principles ("APPs");

(c) the Personal Data Protection Act 2012 of Singapore ("Singapore PDPA");

(d) the Law on Personal Data Protection of Vietnam and Decree No. 13/2023/ND-CP on Personal Data Protection ("Vietnam PDPL");

(e) Law No. 27 of 2022 on Personal Data Protection of Indonesia ("Indonesia PDP Law"); and

(f) Republic Act No. 10173 – the Data Privacy Act of 2012 of the Philippines ("Philippines DPA"),

together with any other applicable data protection laws (collectively, the "Applicable Privacy Laws").

By accessing our website, submitting any information to us, or using our services, you acknowledge that you have read, understood and consented to the practices described in this Policy.
 

1. Definitions

"Assessment" means the report, score, profile, analysis or consultation output generated by TalentsTech using inputs collected from you, including Biometric Data.

"Biometric Data" means fingerprint images, fingerprint templates, derived biometric identifiers and feature vectors collected from you for the purpose of generating an Assessment. Biometric Data is treated as sensitive personal data / sensitive personal information under the Applicable Privacy Laws.

"Personal Information" means any information or opinion about an identified or reasonably identifiable individual, including "personal data" (Malaysia, Singapore, Vietnam, Indonesia), "personal information" and "sensitive information" (Australia), and "personal information" and "sensitive personal information" (Philippines).

"TalentsTech Platform" means the proprietary software, systems, databases and servers owned and operated by Talents Tech Executive Sdn. Bhd. in Malaysia, which constitutes the sole environment in which Personal Information is processed and stored.
 

2. Centralised Processing in Malaysia

2.1 All TalentsTech software, systems, servers and databases are owned, hosted, controlled and operated by Talents Tech Executive Sdn. Bhd. in Malaysia. Malaysia is the sole jurisdiction in which Personal Information collected through our services is processed and stored.

2.2 Users located outside Malaysia — including in Australia, Singapore, Vietnam, Indonesia and the Philippines — access the TalentsTech Platform on a remote-access basis only. No Personal Information is processed, stored or hosted on local systems, servers or devices belonging to TalentsTech's branch offices, affiliates or authorised partners outside Malaysia.

2.3 By accessing the TalentsTech Platform or providing Personal Information to us from any country, you acknowledge and expressly consent that:

(a) your Personal Information will be transmitted to, processed and stored in Malaysia;

(b) the laws of Malaysia, including the Malaysian PDPA, will apply to the processing of your Personal Information; and

(c) such transmission constitutes a cross-border transfer of Personal Information for the purposes of the Applicable Privacy Laws of your jurisdiction.
 

3. Information We Collect

3.1 Information you provide to us. We collect information you submit through the TalentsTech Platform, registration forms, surveys, questionnaires, contests, emails or otherwise, including your name, gender, date of birth or age, contact details, postal and email addresses, and optional biographical information.

3.2 Information collected automatically. When you interact with the TalentsTech Platform, we automatically collect technical information including your IP address, device identifiers, browser type, cookie data, pages requested, and game, test and training program usage data.

3.3 Biometric Data. We collect Biometric Data, specifically fingerprint records of all ten (10) fingers, using a certified biometric capture device. Biometric Data is collected solely for the purpose of generating your Assessment and the related analysis and consultation services. Biometric Data captured at any location worldwide is transmitted directly to and processed on the TalentsTech Platform in Malaysia.

3.4 Collection from third parties. Where you access our services through a sponsoring organisation (such as an employer, recruiter, school or partner agency), we may receive Personal Information about you from that organisation. We rely on that organisation having obtained the necessary consents from you.
 

4. Consent

4.1 By providing Personal Information to TalentsTech, you give your express and informed consent to the collection, use, storage, disclosure, transfer to Malaysia, and processing of that information for the purposes described in this Policy.

4.2 In the case of Biometric Data, you provide your explicit, specific and informed consent in accordance with the heightened consent requirements applicable to sensitive personal data under each of the Applicable Privacy Laws, including:

(a) "explicit consent" under the Malaysian PDPA;

(b) "consent to the collection of sensitive information" under APP 3.3 (Australia);

(c) consent for processing under the Singapore PDPA;

(d) the express consent requirements under the Vietnam PDPL;

(e) the explicit consent requirements under Article 4 of the Indonesia PDP Law; and

(f) the requirements for processing sensitive personal information under Section 13 of the Philippines DPA.

You acknowledge that the collection of Biometric Data is reasonably necessary for the generation of your Assessment, that the purpose, use, retention period and recipients have been clearly explained to you prior to collection, and that you have provided your Biometric Data voluntarily.

4.3 You may withdraw your consent at any time by contacting our Privacy Officer using the details in clause 18. Withdrawal of consent will not affect the lawfulness of processing carried out prior to withdrawal, and may result in our inability to provide some or all of our services to you, including the termination of your account and the permanent loss of access to your Assessment.
 

5. How We Use Your Personal Information

We use your Personal Information for the following purposes:

(a) to verify your identity and authenticate your access to the TalentsTech Platform;

(b) to generate, deliver, support and explain your Assessment;

(c) to provide your Assessment to authorised third parties where you or your sponsoring organisation has directed us to do so;

(d) to manage, maintain, secure and improve our website, services, programs and products;

(e) to communicate with you, including delivering marketing information where you have explicitly opted in;

(f) to detect, prevent and investigate fraud, misuse, security incidents or unauthorised access;

(g) to comply with our legal, regulatory, taxation and record-keeping obligations; and

(h) for research, statistical and analytical purposes, on a de-identified or aggregated basis.
 

6. Biometric Data Handling and Purge Procedure

6.1 TalentsTech operates a strict biometric data minimisation procedure. In accordance with our standard global procedure, all ten (10) fingerprint records, templates and derived biometric identifiers are purged from the TalentsTech Platform once the related Assessment has been generated. This practice is applied uniformly to all users worldwide.

6.2 You acknowledge and agree that:

(a) any residual copies of Biometric Data that may exist transiently in backup or disaster-recovery media maintained on the TalentsTech Platform in Malaysia will be overwritten in the ordinary course of our backup rotation cycles;

(b) once your Biometric Data has been purged, it cannot be recovered, regenerated or reproduced; and

(c) TalentsTech is not obliged to retain Biometric Data for any longer than is necessary to generate your Assessment.

6.3 We implement appropriate technical and organisational security measures to protect Biometric Data during the limited period it is held, including access controls, encryption in transit, and restricted processing environments.
 

7. Retention of Personal Information

7.1 We retain Personal Information (other than Biometric Data, which is governed by clause 6) only for as long as is reasonably necessary for the purposes for which it was collected, or as required or authorised by Applicable Privacy Laws and other applicable laws (including taxation, employment, anti-money-laundering and dispute-resolution laws).

7.2 When Personal Information is no longer required, we will take reasonable steps to destroy or de-identify it in a secure manner.
 

8. Disclosure of Personal Information to Third Parties

8.1 We do not sell, trade or rent your Personal Information.

8.2 We may disclose your Personal Information to:

(a) authorised service providers, data processors and contractors who assist us in operating the TalentsTech Platform (such as IT, hosting, analytics, payment processing and customer support providers engaged by our Malaysian head office), subject to confidentiality and data-protection obligations;

(b) your sponsoring organisation or other authorised recipients of your Assessment, where you have consented or directed us to do so;

(c) professional advisers, including lawyers, accountants and auditors;

(d) regulators, law enforcement agencies, courts or other governmental authorities, where required or permitted by law, subpoena, search warrant or other legal process;

(e) any party to whom disclosure is reasonably necessary to enforce our terms and conditions, protect our rights, property or safety, or the rights, property or safety of our users or others; and

(f) any successor entity in the event of a reorganisation, merger, acquisition, sale of assets or insolvency, in which case Personal Information may be transferred as part of the transaction.

8.3 Where Personal Information is shared for research, statistical or service-improvement purposes, it will be disclosed in aggregated or de-identified form only.
 

9. Cross-Border Transfers to Malaysia

9.1 Because the TalentsTech Platform is owned and operated solely from Malaysia, any user accessing the service from outside Malaysia necessarily transmits their Personal Information to Malaysia for processing and storage. By using our services, you expressly consent to this cross-border transfer.

9.2 We rely on one or more of the following mechanisms to ensure such transfers are conducted lawfully under each Applicable Privacy Law:

(a) your express consent to the transfer, given through your acceptance of this Policy and at the point of providing Personal Information;

(b) the transfer being necessary for the performance of a contract between you and TalentsTech, or for the taking of pre-contractual steps at your request; and

(c) appropriate contractual and organisational safeguards applied within the TalentsTech group.

9.3 Without limiting clause 9.2, you acknowledge that:

(a) for the purposes of Australian Privacy Principle 8, you have been informed of, and consent to, the disclosure of your Personal Information to TalentsTech's Malaysian head office, and APP 8.1 does not apply to such disclosure to the extent permitted by the Privacy Act 1988 (Cth);

(b) for the purposes of the Singapore PDPA, you consent to the transfer of your Personal Information to Malaysia and acknowledge that TalentsTech takes appropriate steps to ensure a comparable standard of protection;

(c) for the purposes of the Vietnam PDPL, you consent to the transfer of your Personal Information outside Vietnam, and TalentsTech will complete any applicable transfer impact assessment and notification requirements where required;

(d) for the purposes of the Indonesia PDP Law, you consent to the transfer of your Personal Information outside Indonesia, and TalentsTech ensures equivalent or higher protection through binding internal safeguards; and

(e) for the purposes of the Philippines DPA, TalentsTech remains accountable for Personal Information transferred to Malaysia and ensures appropriate contractual and organisational safeguards.

9.4 TalentsTech does not maintain local servers, databases or copies of Personal Information in Australia, Singapore, Vietnam, Indonesia or the Philippines. All branch offices, affiliates and authorised partners outside Malaysia access the TalentsTech Platform on a controlled, remote-access basis only.

9.5 We may also disclose Personal Information where required by law, legal process, or requests from public or governmental authorities within or outside your country of residence, or where we determine that disclosure is reasonably necessary for purposes of national security, law enforcement or other matters of public importance.
 

10. Your Rights

Subject to Applicable Privacy Laws and verification of your identity, you have the right to:

(a) request access to the Personal Information we hold about you;

(b) request correction of inaccurate, outdated, misleading or incomplete information;

(c) request deletion or erasure of your Personal Information and Biometric Data;

(d) withdraw your consent to processing (subject to clause 4.3);

(e) request restriction of, or object to, certain processing, where such a right is provided under Applicable Privacy Laws; and

(f) lodge a complaint with us or with the relevant regulator (see clause 16).

To exercise any of these rights, please contact our Privacy Officer using the details in clause 18. We will respond to verified requests within thirty (30) days, or such other period as required by Applicable Privacy Laws.

You acknowledge that:

(i) we may require you to verify your identity before actioning any request;

(ii) once your Personal Information has been deleted, your account will be closed and your online Assessment report will no longer be available, and this action is irreversible;

(iii) we are not obliged to re-issue, reconstruct or reproduce any Assessment, report or related output following deletion; and

(iv) where we are required or authorised by law to retain certain records, those records will be securely quarantined and retained for the period required by law before being destroyed or de-identified.
 

11. Children and Minors

We take additional care to protect the privacy of children and minors. Children under the age of thirteen (13), or the higher minimum age applicable in the relevant jurisdiction, are not permitted to use TalentsTech's services unless their parent or legal guardian has provided verifiable consent in accordance with our Consent to TalentsTech's Collection, Use and Disclosure of Your Child's Information.

Schools or other educational organisations participating in TalentsTech's services may facilitate services to children only after reviewing and consenting to the applicable disclosure documentation, and only where appropriate parental consent has been obtained. If we become aware that we have collected Personal Information from a child outside these circumstances, we will take reasonable steps to delete that information promptly.
 

12. Security

12.1 We implement reasonable technical and organisational security measures designed to protect Personal Information against unauthorised access, loss, misuse, alteration or disclosure, including:

(a) SSL/TLS-encrypted communications between user devices and the TalentsTech Platform in Malaysia;

(b) role-based access controls limiting employee access to Personal Information on a strict need-to-know basis;

(c) confidentiality obligations binding all employees, contractors and partners (including Ambassadors, Agents and Representatives), regardless of the country in which they are located;

(d) regular access audits, security reviews and staff training;

(e) restrictions on the use of unapproved or unauthorised network-enabled devices to access the TalentsTech Platform; and

(f) requirements that all remote access by branch offices, affiliates and authorised partners be conducted via secured channels approved by our Malaysian head office.

12.2 Customer Service Representatives and support personnel may not access customer-level Personal Information without explicit authorisation from the customer or as required to deliver requested support.

12.3 While we take reasonable steps to protect Personal Information, no system or method of transmission over the internet is completely secure. To the extent permitted by law, you provide your Personal Information at your own risk and acknowledge that TalentsTech cannot guarantee absolute security.
 

13. Data Breach Notification

In the event of a data breach that is likely to result in significant harm or otherwise triggers notification obligations, TalentsTech will comply with all applicable breach notification requirements, including:

(a) the mandatory breach notification requirements under the Malaysian PDPA (as the primary jurisdiction of processing);

(b) the Notifiable Data Breaches scheme under the Australian Privacy Act 1988 (Cth);

(c) the mandatory data breach notification obligations under the Singapore PDPA;

(d) the breach notification obligations under the Vietnam PDPL (including notification to the Ministry of Public Security within seventy-two (72) hours where required);

(e) the breach notification obligations under the Indonesia PDP Law (notification within seventy-two (72) hours); and

(f) the breach notification obligations under the Philippines DPA (notification to the National Privacy Commission and affected individuals within seventy-two (72) hours where required).
 

14. Cookies, Analytics and IP Addresses

Our website uses cookies and similar standard web technologies to recognise your browser, analyse usage, and improve content. Most browsers allow you to disable cookies; however, some features of our website may not function properly if cookies are disabled.

We use Google Analytics to analyse website audience and improve our content. For information about Google's privacy practices, please see https://policies.google.com/privacy.

Every device connected to the internet is assigned an Internet Protocol (IP) address. We collect and use IP addresses to operate our website, deliver content, detect and prevent fraud and security threats, and for general analytics. IP addresses may be used to derive approximate geolocation information.
 

15. Governing Law

This Privacy Policy and any matters relating to the processing of Personal Information on the TalentsTech Platform are governed by the laws of Malaysia, without regard to its conflict-of-law principles. You agree to submit to the non-exclusive jurisdiction of the courts of Malaysia in respect of any dispute arising from this Policy.

Nothing in this clause limits your right to lodge a complaint with the data protection authority in your country of residence, or to rely on any mandatory rights under the Applicable Privacy Laws of your jurisdiction that cannot be excluded by contract.
 

16. Complaints and Regulators

If you believe we have breached our privacy obligations, please contact our Privacy Officer in the first instance (see clause 18). We will investigate and respond within a reasonable time.

If you are not satisfied with our response, you may lodge a complaint with the data protection authority in your jurisdiction:

(a) Malaysia — Personal Data Protection Commissioner: www.pdp.gov.my;

(b) Australia — Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au; tel. 1300 363 992;

(c) Singapore — Personal Data Protection Commission (PDPC): www.pdpc.gov.sg;

(d) Vietnam — Ministry of Public Security, Department of Cybersecurity and High-Tech Crime Prevention (A05);

(e) Indonesia — the Personal Data Protection Authority established under the Indonesia PDP Law (and, prior to its full operationalisation, the Ministry of Communication and Digital Affairs); and

(f) Philippines — National Privacy Commission: www.privacy.gov.ph.
 

17. Limitation of Liability

To the maximum extent permitted by law, TalentsTech's total aggregate liability arising out of or in connection with the collection, use, storage, disclosure, transfer, retention, deletion or loss of your Personal Information or Biometric Data, or the unavailability of any Assessment following deletion, is limited to the fees paid by you (or on your behalf) to TalentsTech in the twelve (12) months immediately preceding the event giving rise to the claim.

Nothing in this Policy excludes, restricts or modifies any right or remedy that cannot lawfully be excluded, restricted or modified under Applicable Privacy Laws or applicable consumer protection law.
 

18. Changes and Contact

18.1 Changes. We may update this Privacy Policy from time to time. The current version will always be published on our website with its effective date. Where changes are material, we will provide additional notice. Your continued use of our services following any update constitutes your acceptance of the updated Policy.

 

Any other inquiries may be directed to:

​

Privacy Manager
83-1, Jalan BK5A/2, Bandar Kinrara 47180 Puchong, Selangor, Malaysia
Phone: (60) 01116880200 (Malaysia)
Email: info@talentstech.com
 

By using our website or services, you consent to the collection, use, and disclosure of your Personal Information as described in this Privacy Policy.