[ privacy_policy.md ]

Privacy Policy

Last Updated: 31 July 2025

1. Introduction

Gradient Owl (referred to as "we", "us" or "our") operates as an online school providing AI development courses from Unit 7-3, Icon City, Jalan SS 8/39, 47300 Petaling Jaya, Selangor, Malaysia. We are committed to handling personal data responsibly and transparently.

This policy explains what personal data we collect from people who visit our website or enrol in our courses, how we use it, how long we keep it, and what rights you have in relation to it. It applies to all data collected through our website at gradientn.biz and through our course administration systems.

Questions about this policy can be directed to [email protected].

2. Data We Collect

2.1 Information you provide

  • Name and email address submitted through our contact form
  • Phone number if provided voluntarily in the contact form
  • Messages submitted through our enquiry form
  • Exercise submissions and project code submitted as part of course participation
  • Payment information — processed by a third-party payment provider; we do not store full card details

2.2 Information collected automatically

  • Website usage data via analytics cookies (if you have consented)
  • Browser type and operating system (anonymised)
  • Session cookies for site functionality

2.3 Legal basis for processing (PDPA Malaysia)

We process personal data under the Personal Data Protection Act 2010 (PDPA) of Malaysia. The lawful bases we rely on are: your consent (for marketing communications and optional cookies), the performance of a contract (to deliver course services to enrolled learners), and our legitimate interest (to respond to enquiries and maintain course records).

2.4 Retention periods

  • Enquiry data (non-enrollees): deleted 12 months after the last contact
  • Enrolment and course records: kept for 5 years following course completion for administrative and legal purposes
  • Exercise submissions and project code: deleted 6 months after course completion unless you request otherwise
  • Analytics data: retained in anonymised form in accordance with our analytics provider's policy

3. How We Use Your Data

We use the data we collect for the following purposes:

  • Responding to enquiries submitted through our contact form
  • Managing course enrolment, access to learning materials and cohort forums
  • Delivering written feedback on exercises and managing mentor calls
  • Issuing completion records and course-related correspondence
  • Processing payments through our payment provider
  • Understanding how the website is used so we can improve it (analytics, where consented)
  • Sending course-related updates to enrolled learners

We do not sell personal data to third parties. We do not use your data for advertising profiles or share it with advertisers.

4. Data Protection Measures

Personal data is stored on secured servers with access restricted to staff who require it for course administration. Data in transit between your browser and our systems is encrypted using TLS.

Exercise submissions and project code submitted by learners are accessible only to the relevant course instructor and are not shared with other cohort members or third parties.

In the event of a data breach affecting your personal data, we will notify you and the relevant authorities as required under Malaysian law within the applicable timeframes.

5. Cookies

Our website uses essential cookies for basic functionality and optional analytics cookies to understand site usage patterns. You can manage cookie preferences through the consent notice that appears on your first visit. For full details, see our Cookie Policy.

6. Your Rights

Under the PDPA Malaysia and applicable data protection principles, you have the following rights in relation to your personal data:

  • Access: You may request a copy of the personal data we hold about you.
  • Correction: You may request that inaccurate or incomplete data be corrected.
  • Erasure: You may request deletion of your personal data where we no longer have a lawful basis to retain it.
  • Withdrawal of consent: Where we process data based on consent, you may withdraw it at any time. This does not affect the lawfulness of processing carried out before withdrawal.
  • Objection: You may object to processing carried out on the basis of legitimate interest.
  • Complaint: You may lodge a complaint with the Department of Personal Data Protection Malaysia (JPDP) if you believe your rights have been infringed.

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

7. Third-Party Links and Services

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites. We recommend reviewing the privacy policy of any third-party site you visit.

We use a third-party payment processor to handle payments securely. We do not store full card details. Our payment provider's own privacy policy governs how they handle your payment data.

Cloud compute environments used in our courses are provided by third-party infrastructure providers. Learner code run in those environments is subject to those providers' terms of service.

8. Children's Privacy

Our courses are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently received data from a minor, please contact us at [email protected] and we will delete it promptly.

9. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or legal obligations. Material changes will be communicated to enrolled learners by email and noted on this page with an updated date. Continued use of our website or courses after the effective date of a change constitutes acceptance of the updated policy.

10. Contact for Privacy Matters

Data controller: Gradient Owl

Address: Unit 7-3, Icon City, Jalan SS 8/39, 47300 Petaling Jaya, Selangor, Malaysia

Email: [email protected]

Phone: +60 12-874 3096