Privacy Policy

1. Introduction

Nomera ("we", "us", "our") is committed to handling personal data responsibly and in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA 2010). This policy explains what data we collect, why we collect it, how we use it, and the rights you have in relation to it.

This policy applies to data collected through our website at nomeraxx.pro and through the course of our advisory engagements. Questions about this policy may be directed to [email protected].

2. Data We Collect

We collect personal data through the following means:

• Contact forms submitted through our website (name, email address, telephone number, message content)
• Email and telephone communications with us before and during an engagement
• Documents provided in the course of an engagement (employment contracts, notices, correspondence)
• Cookies and analytics tools placed on our website (see Section 5)

We collect only the data needed for the purpose stated at the time of collection. We do not collect sensitive personal data (such as health or financial data) unless it is directly relevant to an engagement and you have provided it voluntarily.

3. How We Use Your Data

Personal data is used for the following purposes:

• Responding to enquiries submitted through our website or by telephone or email
• Delivering the advisory services described in your engagement letter
• Maintaining records of engagements in accordance with professional obligations
• Sending administrative information related to your engagement (invoices, updates, engagement letters)
• Improving our website and understanding how it is used (analytics, aggregated only)

The legal bases for processing are: performance of a contract or pre-contractual steps (engagement delivery), compliance with legal obligations (record-keeping), and legitimate interests (website analytics and service improvement).

4. Data Retention

Engagement documents and correspondence are retained for a period of seven years from the close of the engagement, consistent with professional record-keeping obligations under Malaysian law. Website enquiry data that does not progress to an engagement is retained for 12 months and then deleted.

Analytics data collected through cookies is retained in accordance with the third-party service provider's standard retention periods, typically no longer than 26 months.

5. Cookies

Our website uses cookies to understand how it is used and to improve the experience for visitors. We use essential cookies (required for the site to function), analytics cookies (aggregated usage statistics), and optional preference cookies. You can manage your cookie preferences at any time through our Cookie Policy page.

6. Data Sharing

We do not sell, rent, or share personal data with third parties for marketing purposes. Data may be shared with:

• Service providers who assist with website hosting, analytics, and communications (subject to data processing agreements)
• Professional advisers where required for the delivery of an engagement (with your knowledge)
• Regulatory authorities or courts where disclosure is required by law

7. Data Protection Measures

We maintain technical and organisational measures to protect personal data from unauthorised access, disclosure, or loss. These include secure storage systems, access controls, and staff awareness of data handling obligations under the PDPA 2010. In the event of a data breach that is likely to affect your rights, we will notify you and the relevant authority within the timeframes required by law.

8. Your Rights

Under the PDPA 2010 and applicable law, you have the following rights in relation to your personal data:

• Right to access personal data we hold about you
• Right to correct inaccurate or incomplete data
• Right to withdraw consent to processing (where consent is the legal basis)
• Right to request deletion of data that is no longer required
• Right to object to processing on grounds of legitimate interests
• Right to lodge a complaint with the Personal Data Protection Commissioner (Malaysia)

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

9. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and recommend you review their privacy policies before providing any personal data.

10. Children

Our services are directed at individuals aged 18 and above. We do not knowingly collect personal data from minors. If you believe a minor has provided data to us, please contact us and we will arrange deletion promptly.

11. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated by updating the "Last updated" date at the top of this page. Continued use of our services following an update constitutes acceptance of the revised policy.

12. Contact

Data controller: Nomera, 8-3, Plaza Damas, Jalan Sri Hartamas 1, Sri Hartamas, 50480 Kuala Lumpur.

Privacy enquiries: [email protected]