Privacy Policy

Last updated: 25 October 2026 (draft)

[TBD: counsel review pending. Bracketed items are open.]

This policy explains how CLOSA.my ("we") handles personal data when you use our app, web dashboard and Digital Showroom. It is written to comply with Malaysia's Personal Data Protection Act 2010 (PDPA). If you are a buyer who dealt with a Sales Advisor who uses CLOSA.my, please read the Buyer Privacy Notice.

Senarai menunggu Founding SA / Founding SA waitlist

[DRAF — perlu semakan legal-compliance-my sebelum diterbitkan. / DRAFT — needs legal-compliance-my review before publish.]

Versi Bahasa Malaysia

Jika anda menyertai senarai menunggu Founding SA, kami mengumpul: nama penuh, nombor WhatsApp, jenama, dealer/kawasan, masa persetujuan, dan cap (hash) garam bagi alamat IP anda untuk mencegah penyalahgunaan — kami tidak menyimpan alamat IP mentah.

Tujuan: menghubungi anda melalui WhatsApp tentang akses awal sahaja. Kami tidak menjual data anda kepada pihak ketiga dan tidak menggunakannya untuk pemasaran pihak ketiga.
Siapa boleh akses: pengasas dan kakitangan CLOSA sahaja.
Tempoh simpanan: [TODO(legal): tempoh simpanan] — jangan andaikan sebarang tempoh sehingga penasihat mengesahkannya.
Tarik balik / padam: balas STOP di WhatsApp atau hubungi [TODO: saluran hubungan] untuk meminta data anda dipadam.

English version

If you join the Founding SA waitlist, we collect: full name, WhatsApp number, brand, dealer/area, time of consent, and a salted hash of your IP address for abuse prevention — we do not store the raw IP address.

Purpose: to contact you via WhatsApp about early access only. We do not sell your data to third parties and do not use it for third-party marketing.
Who can access: CLOSA founders and staff only.
Retention: [TODO(legal): retention period] — do not assume any period until counsel confirms it.
Withdraw / delete: reply STOP on WhatsApp or contact [TODO: contact channel] to request deletion of your data.

1. Who we are and our role

CLOSA.my is operated by [TBD: legal entity name, e.g. Pixel 48 Studio, SSM no., registered address].

Your own account data (name, email, phone, billing, how you use the service): we are the data user.
Buyer and customer data you put into CLOSA.my (leads, documents, notes): you (or your Agency) decide why and how it is used. We process it on your behalf as your data processor, only to provide the service.

2. What we collect

From you (Sales Advisor or Agency user)

Account details: name, email, phone/WhatsApp number, brands you sell, dealership or agency.
Public Showroom profile: name, photo, contact buttons, content you choose to publish.
Onboarding answers: tapped chips about your business (role, brands, volumes). No free text and no buyer data.
Billing: plan, invoices, payment-gateway reference. We never see or store your full card number.
Your contact book of bankers (name, email, phone, bank, branch) used to send loan dossiers.
Technical and security records: sign-in events, IP address, device/browser, activity and access logs.

About buyers (entered by you or submitted by the buyer)

Contact: name, phone/WhatsApp, from the Showroom enquiry form or entered by you.
Lead data: interested model/variant, pipeline stage, outcome, notes, booking and loan status.
Supporting documents: IC (MyKad), driving licence, payslips, bank and EPF statements. The IC number you enter is stored encrypted and is shown only on the front page of the bank dossier.
Optional reviews: rating, text, display name and (with separate consent) a photo, shown publicly on your Showroom.

3. Why we use it

To provide the service: catalog, pipeline, Document Vault, quote posters, Showroom, bank dossiers.
To bill you and manage trials, plans and lapses.
To secure the service, prevent abuse, and keep an audit trail of who accessed which document.
To send service messages (verification, billing, loan-dossier delivery, in-app notifications).
To understand and improve the product using first-party, aggregated usage data.

We do not sell personal data and we do not use buyer documents or lead data for advertising.

4. Who we share it with

Banks and bankers you choose. When you submit a loan dossier, the bank officer receives the documents through a time-limited, access-logged link. What happens after that is governed by the bank's own policies.
Service providers (sub-processors): cloud hosting and object storage [TBD: VPS provider, Cloudflare R2/CDN], email delivery (Amazon SES, Singapore region), payment processing ([TBD: Stripe / Billplz]). Each is bound by confidentiality and security obligations.
WhatsApp (Meta). When you tap a WhatsApp action, the message is sent from your own phone and number. CLOSA.my does not send messages on your behalf at MVP. Meta's own privacy terms apply to anything you send.
Your Agency. If you were added under an Agency plan, Agency admins can see and manage team leads, and the Agency holds leads it added if you leave.
Authorities where the law requires it.

5. Transfers outside Malaysia

Some providers store or process data outside Malaysia (for example email delivery in Singapore and a global CDN). We choose providers that offer appropriate safeguards and, where available, Asia-Pacific regions. [TBD: confirm hosting regions before launch.]

6. How long we keep it

Data	Retention
Supporting documents (IC, licence, payslips, statements)	Automatically and verifiably deleted 180 days after the lead is Closed or Cancelled. The bank holds the authoritative loan documents, not us.
CRM and lead data	Deleted 30 days after your subscription becomes inactive.
Account	Removed 60 days after your subscription becomes inactive (see Billing & Refunds).
Document access and audit metadata; billing records	7 years (accountability and legal obligations). These contain metadata, not document contents.
Security logs	12 to 24 months.
Onboarding funnel events	Deleted with CRM data at 30 days, otherwise pruned after 180 days.

Reviews you publish can be removed at any time on request: they are unpublished, deleted, and the Showroom is regenerated. Copies a person has already downloaded or forwarded are outside our control.

7. How we protect it

Encryption in transit (TLS) and at rest for documents and sensitive fields.
Short-lived, signed links for document access; every view, export and delete is logged.
Buyer-upload links are scoped, expiring and revocable; uploads are rate-limited and type/size-checked.
Card details are held by the payment gateway, never by us.
No personal data in application logs.

No system is perfectly secure. If a breach affects your data we will notify you, and the regulator where the law requires.

8. Cookies and analytics

We use strictly necessary cookies to keep you signed in and protect your session.
We measure product usage with self-hosted, first-party tools. No third-party analytics run on the buyer Tracker, bank dossier or document vault.
Public Showroom pages are static and load no third-party scripts by default. If a Sales Advisor adds their own Google Analytics ID or embeds a video (YouTube, TikTok, Instagram), that provider may set its own cookies on that visitor; the embed loads only when the visitor taps play. [TBD: confirm platform GA4/GTM use on closa.my.]

9. Your rights

Under the PDPA you may ask to:

access the personal data we hold about you;
correct inaccurate data;
withdraw consent or limit processing (this may mean we can no longer provide the service);
delete data (audit and billing records we must keep by law are exempt).

Email [TBD: privacy@closa.my]. We may need to verify your identity and aim to reply within 21 days. To reach data about you that a Sales Advisor holds as a buyer, see the Buyer Privacy Notice.

10. Children

CLOSA.my is for business use by adults. We do not knowingly collect data from children.

11. Changes

We will update this page and, for material changes, notify you in the app or by email before they take effect.

12. Contact

[TBD: privacy@closa.my], [TBD: postal address]. Data protection contact: [TBD: name / role].